On December 7, 2012, the Internal Revenue Service (IRS) released its 2012 cumulative list of changes in plan qualification requirements. The cumulative list contained in Notice 2012-76 should be used by plan sponsors and practitioners submitting determination letter applications from February 1, 2013, through January 31, 2014.
Pension plans using the list will primarily be single-employer individually designed defined contribution plans and single-employer individually designed defined benefit plans that are in Cycle C, and Section 414(d) governmental plans that choose to file during Cycle C. In general, an individually designed plan is in Cycle C if the last number of the plan sponsor's employer identification number (EIN) is three or eight.
The 2012 cumulative list reflects changes under the:
Pension Protection Act (PPA) of 2006;
US Troop Readiness, Veterans' Care, Katrina Recovery and Iraq Accountability Appropriations Act, 2007;
Heroes Earnings Assistance and Relief Tax Act of 2008 (HEART Act);
Worker, Retiree, and Employer Recovery Act of 2008 (WRERA);
Small Business Jobs Act of 2010 (SBJA);
Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 (PRA 2010); and
Moving Ahead for Progress in the 21st Century Act (MAP-21).
The 2012 cumulative list does not extend the deadline by which a plan must be amended to comply with statutory, regulatory or guidance changes. While the 2012 cumulative list informs plan sponsors of issues the IRS identified for review in determining whether a plan has been properly updated, the IRS emphasizes that a plan still must comply with all qualification requirements, not just those on the 2012 cumulative list.
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