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
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
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
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
As we previously reported, the Internal Revenue Service (the “Service”) scaled back its determination letter program for individually designed retirement plans effective as of January 1, 2017. In the intervening years, the...more
The IRS announced April 5 that it is considering opening its determination letter program again to certain types of individually designed retirement plans. In 2016, the IRS announced that it would stop making routine...more
Effective January 1, 2017, except for the last batch of Cycle A filers who were permitted to submit determination letters by January 31, 2017 (i.e., filers with an EIN ending in 1 or 6), the IRS will no longer accept...more
This advisory reminds plan sponsors of deadlines for amending qualified retirement plans and for submitting certain plans to the IRS for a determination letter, as well as other significant changes to the determination letter...more
For many months, we have been speculating about how the results of the 2016 presidential election would impact employee benefits policy going forward. Now that Donald Trump has won the election and Republicans have secured a...more
On September 16, 2016, the IRS and the Department of the Treasury requested public comment on ways the IRS and Treasury “can improve compliance…by making it easier for plan sponsors to satisfy requirements for qualified plan...more
As was previously announced in 2015, effective as of January 1, 2017, the Internal Revenue Service (“IRS”) is eliminating its five year staggered determination letter cycle for individually designed retirement plans. Plans in...more
The Internal Revenue Service recently issued Revenue Procedure 2016-37, which sets forth in detail the significant changes to the IRS’s determination letter program for qualified retirement plans, which we have written about...more
In Announcement 2015-19, the IRS announced the elimination of the five year remedial amendment cycle for individually designed retirement plans effective as of January 1, 2017. This means that after January 1, 2017,...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
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