The IRS recently issued five more Private Letter Rulings ("PLR") confirming that defined benefit plans that offer a limited-time lump-sum distribution option to participants already in pay status will not violate the provisions of Code section 401(a)(9) requiring qualified plans to make yearly minimum distributions to plan participants.  The PLRs specifically provide that the by issuing the PLRs, the IRS is not opining on whether the specific limited-time offers meet other Code requirements, including the requirements of Code section 417(e), related to minimum present value.

A PLR is only binding precedent with respect to the taxpayer that requested the opinion.