News & Analysis as of

Benefit Plan Sponsors Hybrid Plan

Seyfarth Shaw LLP

Hybrid Plan Filing Reprieve…. Sort of

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS published guidance in its Employee Plans newsletter on August 24, 2020, allowing incomplete determination letter applications to be filed by August 31, 2020, with an opportunity to supplement the...more

Locke Lord LLP

IRS Reopens Determination Letter Program for Certain Individually Designed Plans

Locke Lord LLP on

In 2017, the IRS significantly limited the ability of plan sponsors to request a determination letter that its individually-designed retirement plan met the tax qualification requirements of the Internal Revenue Code. Since...more

Snell & Wilmer

2019 End of Year Plan Sponsor “To Do” List (Part 3) Qualified Retirement Plans

Snell & Wilmer on

As 2019 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered health and welfare...more

Troutman Pepper

Limited Opportunity to Apply for an IRS Determination Letter for Cash Balance Plans

Troutman Pepper on

For the one-year period beginning September 1, 2019 and ending August 31, 2020, plan sponsors of statutory hybrid plans will be able to apply for a favorable determination letter from the IRS....more

McDermott Will & Emery

Right Around the Corner: Expanded IRS Determination Letter Program Opens in September

McDermott Will & Emery on

Beginning September 1, 2019, the IRS is expanding its retirement plan determination letter program to apply to certain individually designed statutory hybrid and merged plans. Employers sponsoring hybrid plans not previously...more

King & Spalding

Compensation and Benefits Insights – July 2019

King & Spalding on

In May 2019, the IRS issued Revenue Procedure 2019-20, which provides for a limited expansion of the determination letter program for certain individually-designed plans. Under this expansion, the IRS will accept...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

A Welcome Expansion: IRS Resuscitates Determination Letter Program

Beginning September 1, 2019, employers that sponsor cash balance plans and certain merged plans can sleep easier. Revenue Procedure 2019-20, issued by the Internal Revenue Service (IRS) on May 1, 2019, opens the IRS’s...more

Foley & Lardner LLP

Should I Be Getting an Updated IRS Determination Letter?

Foley & Lardner LLP on

If you maintain a qualified retirement plan, such as a 401(k) or pension plan, that covers more than 100 employees, you are likely in the midst of your annual plan audit. During this process, your auditor might ask for a copy...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Reopens Determination Letter Program for Hybrid and Merged Plans

Employers have new opportunity to obtain IRS approval of individually designed plan documents. Individually designed cash balance plans and other “statutory hybrid” pension plans can be submitted for IRS approval during...more

Faegre Drinker Biddle & Reath LLP

IRS Announces Limited Expansion of the Determination Letter Program for Individually Designed Plans

Since the end of the IRS’s cyclical determination letter program for individually designed retirement plans in 2017, plan sponsors have been able to request favorable determination letters for individually designed plans only...more

Bradley Arant Boult Cummings LLP

IRS Expands Determination Letter Program - Employee Benefits Alert

The Internal Revenue Service (IRS) has expanded the determination letter program for individually designed plans. Under Revenue Procedure 2019-20, the IRS will now accept determination letter applications for statutory hybrid...more

Ballard Spahr LLP

IRS Expands Determination Letter and Self-Correction Programs

Ballard Spahr LLP on

The IRS announced yesterday that it will expand its determination letter program for tax-qualified retirement plans. Under previous IRS procedures, a plan sponsor could submit its plan document to the IRS, and the IRS would...more

Seyfarth Shaw LLP

PBGC Sticks Its Head Out Of The Water And Issues RFI Regarding Hybrid (Two-Pool) Multiemployer Pension Plans

Seyfarth Shaw LLP on

Seyfarth Synopsis: The PBGC is seeking more information on hybrid or two-pool withdrawal liability calculation methods. This is a sign that the PBGC may be re-evaluating its role in approving hybrid proposals, although it...more

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