News & Analysis as of

Revenue Procedures Internal Revenue Service 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

Verrill

New IRS Determination Letter Program for 403(b) and 401(a) Plans

Verrill on

On November 7, 2022, the IRS issued Revenue Procedure 2022-40, which allows certain tax-exempt employers (such as schools, charities, and churches) to apply for IRS determination letters on their individually designed section...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

McDermott Will & Emery

Weekly IRS Roundup December 30, 2019 – January 3, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 30, 2019 – January 3, 2020. December 30, 2019: The IRS issued a news release announcing...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

Holland & Knight LLP

Limited Ability to Submit Your Individually Designed Plan for a Determination Letter

Holland & Knight LLP on

• Effective Sept. 1, 2019, the sponsors of certain retirement plans may submit their plans to the Internal Revenue Service (IRS) for review of a determination letter application. • Revenue Procedure 2019-20 expands the IRS...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

Brownstein Hyatt Farber Schreck

IRS Implements Prospective Expansion of Determination Letter Program to Merged Plans

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

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

Poyner Spruill LLP

IRS Determination Letter Program Broadens Its Reach

Poyner Spruill LLP on

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

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

Proskauer - Employee Benefits & Executive...

IRS Announces Limited Expansion of its Determination Letter Program for Individually Designed Retirement Plans – But Questions...

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

Snell & Wilmer

Reopening the Floodgates: IRS Announces Expanded Determination Letter Program

Snell & Wilmer on

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

McDermott Will & Emery

Maintaining Retirement Plan Documents after Revenue Procedure 2016-37

McDermott Will & Emery on

At the 2016 Joint Fall CLE Meeting on October 1, 2016, Andrew Liazos presented on “Maintaining Retirement Plan Documents after Revenue Procedure 2016-37.” As an employer sponsoring a retirement plan, you are required by...more

Jackson Lewis P.C.

Determination Letter Rationing: IRS Reveals the Brave New World

Jackson Lewis P.C. on

Last year’s announcement by the Internal Revenue Service (IRS) of the elimination of the current five-year remedial amendment cycle system for determination letter approval of restated individually-designed qualified plan...more

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