SECTION 1. PURPOSE

.01 This revenue procedure revises and combines the Service’s master and prototype (M&P) and regional prototype plan programs into a unified program for the pre-approval of pension, profit-sharing, and annuity plans. This revenue procedure opens this unified program, on April 7, 2000, for mass submitter plans and May 8, 2000 , for non-mass submitter plans, to allow sponsors to obtain opinion letters relating to the qualification of their plans which take into account all of the changes in the qualification requirements made by the following:

1 The Uruguay Round Agreements Act, Pub. L. 103–465 (GATT);

2 The Small Business Job Protection Act of 1996, Pub. L. 104–188 (SBJPA) (including § 414(u) of the Internal Revenue Code (Code) and the Uniformed Services Employment and Reemployment Rights Act of 1994, Pub. L. 103–353 (USERRA));

3 The Taxpayer Relief Act of 1997, Pub. L. 105–34 (TRA ‘97); and

4 The Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105–206 (RRA). These acts are hereinafter referred to collectively as GUST.

.02 This revenue procedure also opens the Service’s volume submitter program on March 8, 2000, to allow practitioners to obtain GUST advisory letters for their volume submitter specimen plans.

.03 At the present time, employers may not obtain determination letters that consider all of the requirements of GUST. However, the Service expects to allow employers to obtain complete GUST letters in the near future.