News & Analysis as of

Plan Documents Determination Letter

Morgan Lewis - ML Benefits

IRS: Show Me the Signatures for Qualified Plan Documents

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

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

Troutman Pepper

Limited Opportunity to Apply for an IRS Determination Letter for Cash Balance Plans

Troutman Pepper on

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

King & Spalding

Compensation and Benefits Insights – July 2019

King & Spalding on

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

A Welcome Expansion: IRS Resuscitates Determination Letter Program

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

Pillsbury Winthrop Shaw Pittman LLP

IRS Reopens Determination Letter Program for Hybrid and Merged Plans

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

Bradley Arant Boult Cummings LLP

IRS Expands Determination Letter Program - Employee Benefits Alert

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

Williams Mullen

IRS Announces Changes to Determination Letter Options

Williams Mullen on

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

Ballard Spahr LLP

IRS Expands Determination Letter and Self-Correction Programs

Ballard Spahr LLP on

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

The Grisly Death of Determination Letters for Individually Designed Plans

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

Eversheds Sutherland (US) LLP

The End of an Era—IRS Issues Additional Guidance on End of Determination Letter Application Program

In 2015, the Internal Revenue Service (IRS) announced changes to its existing determination letter program, namely that the staggered remedial amendment cycle for individually designed retirement plans would end effective...more

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