Tax laws have long required that qualified retirement plans timely adopt written plan documents and amendments. But what evidence must a plan sponsor provide to an IRS auditor to prove that they have timely adopted a written...more
Generally, for a tax qualified retirement plan to be adopted, the plan document must be signed and dated by the sponsoring employer and retained. However, in Val Lanes Recreation Center Corp. v. Commissioner of Internal...more
• Effective Sept. 1, 2019, the sponsors of certain retirement plans may submit their plans to the Internal Revenue Service (IRS) for review of a determination letter application. • Revenue Procedure 2019-20 expands the IRS...more
The IRS has issued guidance (Rev. Proc. 2019-20) expanding the determination letter program for certain individually designed plans. ...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 Impact of Changes to the IRS Determination Letter Program - This January 2017 will see the last regular IRS determination letter applications filed for individually designed retirement plans. After this final Cycle A...more
On September 29, 2016, the Internal Revenue Service (IRS) issued Revenue Procedure 2016-51 (Rev. Proc. 2016-51), which updates the Employee Plans Compliance Resolution System (EPCRS) and changes how sanctions will be...more
The Internal Revenue Service recently issued Revenue Procedure 2016-51, a new version of the Employee Plans Compliance Resolution System (EPCRS) to consolidate and update its prior guidance regarding how to correct of errors...more
Editor's Overview - This month, we look at the implications of the two federal district court cases from California that applied the ban on discretionary clauses typically found in ERISA plans to self-insured plans. The...more
With the looming end of the determination letter program as we know it, the IRS has issued an updated Revenue Procedure for the Employee Plans Compliance Resolutions System (EPCRS). Released on September 29, 2016, Rev. Proc....more
In July of 2015, the IRS announced that it would end its regular determination letter program for individually designed plans effective January 1, 2017. At the time of this announcement, many plan sponsors and other...more
At the 2016 Joint Fall CLE Meeting on October 1, 2016, Andrew Liazos presented on “Maintaining Retirement Plan Documents after Revenue Procedure 2016-37.” As an employer sponsoring a retirement plan, you are required by...more
On September 29, 2016, the IRS released new guidelines under its Employee Plans Compliance Resolution System (EPCRS). EPCRS consists of three programs by which plan sponsors can correct plan documentation or operational...more
The Internal Revenue Service (IRS) announced last year that it would end its staggered five-year remedial amendment cycle system for individually designed retirement plans under the determination letter program due to...more
Last summer, the Internal Revenue Service (IRS) announced that its periodic review of individually designed retirement plans to determine the plans’ qualified status will end effective January 31, 2017. In January 2016, the...more
Major Revisions to Qualified Plan Determination Letter Process Announced - Effective January 1, 2017, the staggered five-year determination letter remedial amendment cycles for individually designed plans will be...more
Effective January 1, 2017, the IRS has announced that, due to limited resources, it is eliminating the existing 5-year determination letter application staggered filing cycles for individually designed plans. Off-cycle...more
The Internal Revenue Service ("IRS") announced, on July 21, 2015, a major curtailment of its determination letter program for individually designed qualified retirement plans ("Individually Designed Plans") that will impose...more