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 determination letter applications for “merged plans” on an ongoing basis and for “statutory hybrid plans” (for example, cash balance plans) during a 12-month period beginning September 1, 2019.
Background
Effective in 2017, the IRS began accepting determination letter applications for individually-designed plans only for determinations upon initial plan qualification and qualification upon plan termination. Thus, the IRS is no longer accepting determination letter applications for individually-designed plans under the five-year cycle determination letter program.
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