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ARTICLE · 19 JULY 2016

A Blueprint For Maintaining An Individually Designed Qualified Plan After The IRS's Determination Letter Program Cutback

McDermott Will & Emery
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On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37.

United StatesEmployment and HR
David Rogers
David Rogers
Andrew Liazos
Andrew Liazos
Brian Benko
Brian Benko
Emily Rickard
Emily Rickard
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Summary

On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37. Effective January 1, 2017, employers that sponsor an individually designed qualified retirement plan—a group that includes most large retirement plans—may no longer request periodic determination letters. Instead, the IRS will continue to conduct random audits to assess plan compliance with plan document operational requirements.

In Depth

On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37. Effective January 1, 2017, employers that sponsor an individually designed qualified retirement plan—a group that includes most large retirement plans—may no longer request periodic determination letters. Cycle A, which closes on January 31, 2017, will be the

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