The Tax Reform Act of 1986' is the fourth major tax enactment in four years to have a significant impact on qualified deferred compensation plans. Like the Tax Equity and Fiscal Responsibility Act of 1982,2 this most recent tax legislation substantially affects the use of participant loan provisions in qualified plans. The purpose of this article is to analyze the cumulative technical difficulties that retirement plan designers and administrators should now consider in reviewing the feasibility and operation of participant loan provisions.

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