IRS letter ruling - Cooperative’s allocation of employee pension plan contribution 

February 21:  The IRS today publicly released a private letter ruling* concerning a farmer-owned cooperative’s allocation of a special employee pension plan contribution, and concluding that such allocation must be made between patronage and non-patronage business in the same manner as the cooperative allocates a litigation settlement payment. PLR 201408009 (release date February 21, 2014, and dated November 4, 2013).

Read text of PLR 201408009 [PDF 46 KB]


*Private letter rulings are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and can only be relied upon by the taxpayer to whom issued. It is important to note that, pursuant to section 6110(k)(3), such items cannot be used or cited as precedent. Nonetheless, such rulings can provide useful information about how the IRS may view certain issues.



For more information, contact KPMG’s National Director of Cooperative Tax Services:


David Antoni, in Philadelphia

(267) 256-1627


Or Associate National Director of KPMG’s Cooperative Tax Services


Brett Huston, in Sacramento


(916) 554-1654




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For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

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1801 K Street NW
Washington, DC 20006.

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