News & Analysis as of

Revenue Procedures Benefit Plan Sponsors Determination Letter

Miller Canfield

Individually Designed 403(b) Plans will be Eligible for Determination Letters

Miller Canfield on

​​​​​​​Plan sponsors of individually designed 403(b) plans will soon be able to submit determination letter applications to the IRS. (Individually designed plans are plans using custom documents that have not been preapproved...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

IRS determination letter procedure updated

Rev. Proc. 2002-4 listed the update for requesting Internal Revenue Service (IRS) determination letters, private letter rulings, and other tax advice on employee plan matters. ...more

Seyfarth Shaw LLP

Hybrid Plan Filing Reprieve…. Sort of

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS published guidance in its Employee Plans newsletter on August 24, 2020, allowing incomplete determination letter applications to be filed by August 31, 2020, with an opportunity to supplement the...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

McDermott Will & Emery

Right Around the Corner: Expanded IRS Determination Letter Program Opens in September

McDermott Will & Emery on

Beginning September 1, 2019, the IRS is expanding its retirement plan determination letter program to apply to certain individually designed statutory hybrid and merged plans. Employers sponsoring hybrid plans not previously...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

Holland & Knight LLP

IRS Adds 2019 Updates to Operational Compliance List

Holland & Knight LLP on

• The Internal Revenue Service (IRS) has updated its Operational Compliance List for retirement plans with a number of changes that take effect in 2019, with a focus on changes to hardship distributions. • The Operational...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

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

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

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

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