News & Analysis as of

Voluntary Correction Program Determination Letter

Stinson - Benefits Notes Blog

IRS Memorandum Limits Exceptions for Retaining Signed Retirement Plan Documents – (excuse that “my dog ate my plan documents” will...

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

Holland & Knight LLP

Limited Ability to Submit Your Individually Designed Plan for a Determination Letter

Holland & Knight LLP on

• 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

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

Seyfarth Shaw LLP

IRS Expands Determination Letter Program on a Limited Basis For Certain Individually Designed Plans

Seyfarth Shaw LLP on

On May 1, 2019, the Internal Revenue Service (IRS) issued guidance re-opening its storied determination letter program to hybrid plans and certain plans impacted by plan mergers....more

Brownstein Hyatt Farber Schreck

IRS Implements Prospective Expansion of Determination Letter Program to Merged Plans

The IRS has announced a limited expansion of its determination letter program. Beginning Sept. 1, 2019, the IRS will accept determination letter (“DL”) applications for individually designed merged plans....more

Poyner Spruill LLP

IRS Determination Letter Program Broadens Its Reach

Poyner Spruill LLP on

On May 1, the Internal Revenue Service (IRS) announced an expansion of the existing determination letter submission program. Previously the IRS has only allowed submissions of initial retirement plan qualifications and plan...more

Husch Blackwell LLP

New Opportunity For Certain Retirement Plans To Obtain IRS Determination Letters

Husch Blackwell LLP on

Beginning February 1, 2017, the Internal Revenue Service (IRS) stopped accepting applications for determination letters for individually designed plans, other than for new plans and terminating plans. This change in IRS...more

Proskauer - Employee Benefits & Executive...

IRS Announces Limited Expansion of its Determination Letter Program for Individually Designed Retirement Plans – But Questions...

On May 1, 2019, the IRS released Revenue Procedure 2019-20 which provides for a limited-scope expansion of its determination letter program for individually designed plans. Beginning on September 1, 2019, the IRS will accept...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The end of the determination letter program and what it means

For the past 15 years, it’s been apparent that the Internal Revenue Service (IRS) wanted to be out of the favorable determination letter business. Over time, the IRS was limiting when they would issue determination letters....more

Proskauer - Employee Benefits & Executive...

Annual IRS Revenue Procedure Includes Surprising Change to User Fees

On January 2, 2018, the IRS published its annual bulletin that updates procedures for requesting rulings, determinations, and other guidance from the IRS. As in past years, the bulletin includes new user fees for...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - October 2016

Proskauer Rose LLP on

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

BCLP

IRS Overhauls the Retirement Plan Correction Program

BCLP on

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

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