News & Analysis as of

Qualified Retirement Plans Determination Letter Employee Plans Compliance Resolution System

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

BCLP

IRS Expands Determination Letter Program for Mergers of Qualified Plans Following Corporate Transactions

BCLP on

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

Orrick, Herrington & Sutcliffe LLP

New IRS Corrections Guidance Puts A Premium On Careful Qualified Plan Drafting

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

Kilpatrick

IRS Provides Guidance for the Post-Determination Letter Era

Kilpatrick on

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

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

Dickinson Wright

The IRS Overhaul of the Determination Letter Process: What Plan Sponsors Need to Know

Dickinson Wright on

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

Bond Schoeneck & King PLLC

Employee Benefits: A Major Curtailment of the IRS Determination Letter Program Will Impose New Compliance Burdens on Sponsoring...

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

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