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ARTICLE · 17 MAY 2019

IRS Expands Determination Letter Program On A Limited Basis For Certain Individually Designed Plans

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On May 1, 2019, the Internal Revenue Service (IRS) issued guidance re-opening its storied determination letter program to hybrid plans and certain plans impacted by plan mergers.

United StatesEmployment and HR
Jake Downing
Jake Downing
Kaley Ventura
Kaley Ventura
Sarah Touzalin
Sarah Touzalin
Manleen Singh
Manleen Singh
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On May 1, 2019, the Internal Revenue Service (IRS) issued guidance re-opening its storied determination letter program to hybrid plans and certain plans impacted by plan mergers.

Expansion of Determination Letter Program for Hybrid Plans

For twelve months beginning September 1, 2019 and ending August 31, 2020, the IRS will accept determination letter applications for statutory hybrid plans (e.g., cash balance plans and pension equity plans).  The IRS will review any hybrid plan submissions based on the 2017 required amendments list.  Its review will also take into consideration all required amendments lists and cumulative lists issued prior to 2016.  The normal determination letter application procedures for individually designed plans will apply.

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