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ARTICLE · 04 JULY 2019

A Welcome Expansion: IRS Resuscitates Determination Letter Program

Ogletree, Deakins, Nash, Smoak & Stewart
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Beginning September 1, 2019, employers that sponsor cash balance plans and certain merged plans can sleep easier.

United StatesEmployment and HR
David Rosner
David Rosner
Christopher Guthrie
Christopher Guthrie
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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 determination letter program for individually designed "statutory hybrid plans" and certain "merged plans." Plan sponsors will recall that beginning January 1, 2017, the IRS's determination letter program for individually designed plans was significantly curtailed by Revenue Procedure 2016-37. Revenue Procedure 2016-37 provided that plan sponsors of individually designed plans could seek a determination letter from the IRS only for initial plan qualification, plan terminations, or other circumstances to be provided by the IRS at a later time.

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