Determination Letter Program

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Deadlines are a large part of employee benefit plan administration.  The past 12 – 18 months have contributed to potential confusion about standard deadlines and added new deadlines plan administrators will not want to overlook.  During this period, the IRS created a one-time window deadline, published extensions for some plans’ deadlines, and other deadlines were…

On May 1, 2019, the IRS issued Revenue Procedure 2019-20, which reopens the determination letter program in a limited manner for individually designed plans that are merged plans or statutory hybrid plans, such as cash balance plans. The new IRS guidance provides that sponsors of merged plans may request determination letters going forward, while…

Last year’s announcement by the Internal Revenue Service (IRS) of the elimination of the current five-year remedial amendment cycle system for determination letter approval of restated individually-designed qualified plan documents provoked bitter criticism and calls to reverse course. The Service cited budget constraints allowing a median time of only three hours of agent review per…

Preapproved (prototype or volume submitter) defined contribution plans must be restated for the Pension Protection Act by April 30, 2016.

Master and prototype and volume submitter plans are generally required to be updated and restated on a six year cycle. The current cycle for preapproved defined contribution plans ends April 30, 2016. Therefore, if you…

The Internal Revenue Service just made it riskier to maintain a tax-qualified individually-designed retirement plan by eliminating the five-year determination letter remedial amendment cycle for these plans, effective January 1, 2017.

Although determination letters are not required for retirement plans to maintain tax-qualified status under the Internal Revenue Code, virtually all employers sponsoring individually-designed retirement…