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EXHIBIT 99.1
Internal Revenue Service Department of the Treasury
District Director
1100 Commerce street
Dallas, Texas 75242
Employer Identification Number:
Date: DEC 14, 1993 74-2570231
File Folder Number:
760008802
Marine Drilling Management Company Person to Contact:
14141 Southwest Freeway, Suite 2500 Jill Rutherford
Sugar Land, Texas 77478-3435 Contact Telephone Number:
(214) 767-1204
Plan Name:
MARINE DRILLING COMPANIES 401K
PROFIT SHARING PLAN
Plan Number: 001
Dear Applicant:
We have made a favorable determination on your plan, identified above,
based on the information supplied. Please keep this letter in your permanent
records.
Continued qualification of the plan under its present form will depend
on its effect in operation. (See section 1.401-1(b)(3) of the Income Tax
Regulations.) We will review the status of the plan in operation periodically.
The enclosed document explains the significance of this favorable
determination letter, points out some features that may affect the qualified
status of your employee retirement plan, and provides information on the
reporting requirements for your plan. It also describes some events that
automatically nullify it. It is very important that you read the publication.
This letter relates only to the status of your plan under the Internal
Revenue Code. It is not a determination regarding the effect of other federal or
local statutes.
This determination letter is applicable for the amendment(s) adopted on
July 01, 1990.
This letter is based upon the certification and demonstrations you
submitted pursuant to Revenue Procedure 91-66. Therefore, the certification and
demonstrations are considered an integral part of this letter. ACCORDINGLY, YOU
MUST KEEP A COPY OF THESE DOCUMENTS AS A PERMANENT RECORD OR YOU WILL NOT BE
ABLE TO RELY ON THE ISSUES DESCRIBED IN REVENUE PROCEDURE 91-66.
Effective January 1, 1993, all qualified plans must comply with Code
section 401(a)(31). In general, section 401(a)(31) requires plans to permit
participants to elect to have an eligible
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retirement distribution paid directly to an eligible retirement plan in a direct
rollover. This requirement applies to distributions made on or after January 1,
1993, even if the plan is not amended to comply with the provisions until the
last date allowed for making such amendments. Because you did not specifically
ask that this issue be considered, the Service did not review the plan for
compliance with section 401(a)(31). Accordingly, the scope of this determination
letter does not extend to the plan's compliance with section 401(a)(31), and
this determination letter may not be relied upon with respect to that issue. For
more details, see Revenue Procedure 93- 12, 1993-3 I.R.B. 14.
The information on the enclosed addendum is an integral part of this
determination. Please be sure to read and keep it with this letter.
We have sent a copy of this letter to your representative as indicated
in the power of attorney.
If you have questions concerning this matter, please contact the person
whose name and telephone number are shown above.
Sincerely yours,
/s/ GARY O. BOOTH
Gary O. Booth
District Director
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Marine Drilling Management Company
This determination letter also applies to the other members who have adopted
this plan.
