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ARTICLE · 26 JANUARY 2016

IRS Notice 2016-03 Modifies The IRS Determination Letter Program

The IRS recently issued Notice 2016-03 (the "Notice"), addressing several items with respect to changes made to the IRS's determination letter program.

United StatesEmployment and HR

The IRS recently issued Notice 2016-03 (the "Notice"), addressing several items with respect to changes made to the IRS's determination letter program. The Notice also extends the deadline for sponsors to adopt a pre-approved defined contribution plan in certain instances.

The changes at issue were published on July 21, 2015 in IRS Announcement 2015-19. Announcement 2015-19 stated that effective January 1, 2017, the staggered 5-year remedial amendment cycles for individually designed qualified plans will be eliminated, and the scope of the IRS's determination letter program will generally be limited to initial plan qualification, qualification upon plan termination, and certain other limited circumstances. Announcement 2015-19 also stated that sponsors of plans in Cycle A will be able to file for a determination letter between February 1, 2016, and January 31, 2017.

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