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ARTICLE · 06 AUGUST 2015

IRS Determination Letters No Longer Available After 2016

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The IRS recently announced significant changes to its determination letter program that will become effective January 1, 2017 (the "Announcement").

United StatesEmployment and HR
John Cannon, III
John Cannon, III
Doreen Lilienfeld
Doreen Lilienfeld
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The IRS recently announced significant changes to its determination letter program that will become effective January 1, 2017 (the "Announcement").1 These changes essentially eliminate determination letters for individually designed plans that are intended to be qualified under Section 401(a) of the Internal Revenue Code of 1986, as amended ("Plans"), except for new Plans and terminating Plans (the "New Program"). While the New Program will relieve Plan sponsors from the burden of preparing and filing determination letter applications, it will create other burdens for sponsors. Additionally, the New Program will impact service providers to the Plans and other parties. These providers and other parties should begin to consider how they will address this change.

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