A. Advise PMRS on compliance with all tax qualification requirements pursuant to the Internal Revenue Code. B. Provide sophisticated legal advice on federal tax and benefit issues and international tax matters related to PMRS’ investments. C. Provide specific, written recommendations and strategies to achieve and maintain the qualified status of the PMRS plans (collectively, hereinafter, referred to as the “Plans”), including but not limited to, written recommendations on amendments to PMRS’ respective plan documents including statutes, policies, and procedures, to ensure the Plans are in full compliance with the Internal Revenue Code qualification criteria. D. Advise PMRS concerning technical compliance of plan documents, including state laws, rules, administrative policies, and procedures for the Plans administered by PMRS to achieve and maintain the qualified status of the Plans. E. Advise PMRS concerning the operational compliance of Plans to maintain the qualified status of the Plans administered by PMRS. F. Advise PMRS on tax compliance matters related to the PMRS defined benefit and cash balance plans. G. Prepare and file documents with the Internal Revenue Service (“IRS”), or other regulatory bodies, on behalf of the Plans. H. Represent PMRS before the IRS or other regulatory bodies as needed. I. Present legal opinions concerning the reporting and taxation of qualified benefits and investment transactions including obtaining necessary opinions, private letter rulings, and other documents from the IRS, or other state, or federal regulatory, or governing bodies as requested by PMRS. J. Advise and provide legal analysis to PMRS on proposed Commonwealth legislation that may have tax implications to PMRS or their members. K. Advise and provide legal analysis to PMRS on participating in the IRS’ Employee Plans Compliance Resolution System (EPCRS), including self-correction.