The IRS has long permitted sponsors of individually designed pension and 401(k) retirement plans qualified under Section 401(a) of the Code to obtain a favorable determination letter on the status of their tax-qualified...more
The Internal Revenue Service (IRS) has announced that beginning June 1, 2023, it will accept determination letter applications for individually designed 403(b) retirement plans. As background, 403(b) plans are a distinct type...more
The US Internal Revenue Service (IRS) recently issued Revenue Procedure 2022-40 to expand the IRS’s determination letter program to include individually designed 403(b) plans. Previously, the IRS’s determination letter...more
In Revenue Procedure 2022-40, the IRS recently expanded the determination letter program to allow applications by individually-designed 403(b) plans. This expansion will allow 403(b) plan sponsors to request a determination...more
Plan sponsors of individually designed 403(b) plans will soon be able to submit determination letter applications to the IRS. (Individually designed plans are plans using custom documents that have not been preapproved...more
Rev. Proc. 2002-4 listed the update for requesting Internal Revenue Service (IRS) determination letters, private letter rulings, and other tax advice on employee plan matters. ...more
The Internal Revenue Service (IRS) has announced increases to user fees for letter rulings and determinations with respect to employee plans. The increases will take effect on January 4, 2021....more
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
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
At the heart of tax qualified retirement plan compliance is a requirement to timely adopt plans and plan amendments. Failure to adopt plan amendments when required can result in plan disqualification. Accordingly, it is very...more
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
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
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
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
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
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
• The Internal Revenue Service (IRS) has updated its Operational Compliance List for retirement plans with a number of changes that take effect in 2019, with a focus on changes to hardship distributions. • The Operational...more
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
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
The IRS recently reversed course on the availability of the determination letter program for merged qualified retirement plans – thereby providing new alternatives for integrating qualified retirement plan benefits in the...more
The Internal Revenue Service (“IRS”) recently issued guidance on two additional options for sponsors of qualified retirement plans to apply for and receive determination letters on the qualified status of their plans. The IRS...more
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
401(k) Options That Must Be Obligatory For Plan Sponsors. They need to be obligatory. Buying a car isn't easy because it's confusing with the different option packages and trims. Sometimes I jokingly ask whether a...more
As more fully described in our earlier newsletter, in Revenue Procedure 2016-37 the Internal Revenue System (IRS) made significant changes in the procedures governing the issuance of favorable determination letters to the...more
All signs point to the IRS expanding access to the determination letter (“DL”) program for individually designed plans in 2019. This would be a welcome move for employers and other plan sponsors, who have been unable to...more