The Internal Revenue Service (IRS) recently issued General Counsel Memorandum 201634021 (Memorandum), clarifying benefit coverage requirements for employees of a disregarded LLC wholly owned by a single member tax-exempt organization (referred to as a “disregarded entity”). Specifically, the Memorandum concludes that such employees must be permitted to participate in the member’s 403(b) plan and may be permitted to participate in the member’s 457(b) plan.
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