RETIREMENT PLAN DEVELOPMENTS
IRS Opens Determination Letter Program for Hybrid and Merged
Plans
In Revenue Procedure 2019-20 (“Rev. Proc. 2019-20”),
the Internal Revenue Service ("IRS") announced it will
accept determination letter applications for individually designed
statutory hybrid plans during the 12 month period beginning
September 1, 2019. The IRS said it will also accept determination
letter applications for certain individually designed merged plans
on an ongoing basis.
Since the IRS eliminated the remedial amendment cycle review
program in 2017, plan sponsors of individually designed plans could
request determination letters only for initial plan qualification,
qualification upon plan termination, and certain other
circumstances as determined annually by the IRS.