SECTION 18. VS MASS SUBMITTERS
Internal Revenue Bulletin 2004-18 · 2026-10-03 edition · updated 2026-10-04 · United States
.01 Advisory Letters Issued to VS Mass Submitters — EP Rulings and Agreements will, upon request by an VS mass submitter, as defined in section 13.05, issue an advisory letter as to the acceptability of the form of the VS mass submitter’s specimen plan under § 401(a) or § 403(a). .] See section 20 for the address to file the application.
.02 The requirements for the VS mass submitters application are as follows:
(1) The application must include the plan and trust and all the other information required by section 17. The application must include a cover letter that states that at least 30 VS practitioners are submitting applications for advisory letters for identical specimen plans and must certify that each such plan is word-for-word identical to the VS mass submitter specimen plan. The cover letter must provide the name, address, and EIN of each of the VS practitioners.
(2) The application for the VS mass submitter specimen plan must include the required user fee under Rev. Proc. 2004–8. (3) The application must be accompanied by separate advisory letter applications filed by each of the VS practitioners listed in the cover letter.
(4) The required user fee for an identical adopter application under Rev. Proc. 2004–8 must also be submitted.
(5) After the initial submission of advisory letter applications for at least 30 VS practitioners, applications may be filed by other VS practitioners who will sponsor the word-for-word identical plan. A copy of the plan should not be submitted.
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