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Opinion letter

Last Updated March 22, 2009


A written statement issued by the IRS to a plan sponsor as to the acceptability (for purposes of  qualified plans)

  • of the form of a master or prototype plan and any related trust or custodial account under a qualified plan , employee annuity or master trust
  • as to the conformance of a prototype trust, custodial account or annuity with the requirements of Traditional IRAs , SEP IRAs , SIMPLE IRAs and Roth IRAs as applicable.

Opinion letters are issued on:

  • Initial applications
  • Plan amendments
  • Master trusts involving the initial acceptability or amendment of such trusts if they are part of qualified plans  .

Referring Cite

IRM § , Revenue Procedure 2000–20

Additional Helpful Information

  • Opinion letters are issued by (by the Director of  Employee Plans Rulings and Agreements in the Office of the Commissioner, Tax Exempt and Government Entities Division of the IRS
  • Opinions letters are not issued for IRS model IRAs, SEPs or SIMPLES