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ARTICLE · 31 JULY 2015

IRS Overhauls Determination Letter Process For Individually Designed Plans

Reed Smith
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Currently, individually designed retirement plans are subject to a five-year determination letter cycle, which is generally based on the last digit of the plan sponsor's Employer Identification Number ("EIN").

United StatesEmployment and HR
John Martini
John Martini
Lori Atkin
Lori Atkin
Dodi Walker Gross
Dodi Walker Gross
Dennis Bonessa
Dennis Bonessa
Kelly Bley
Kelly Bley
Jenny Ronis
Jenny Ronis
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On July 21, 2015, the Internal Revenue Service ("IRS") released Announcement 2015-19, which significantly limits the circumstances under which the IRS will accept determination letter applications for individually designed retirement plans.

Currently, individually designed retirement plans are subject to a five-year determination letter cycle, which is generally based on the last digit of the plan sponsor's Employer Identification Number ("EIN"). To be "on-cycle," a determination letter application must be filed in the last 12 months of the applicable cycle. A determination letter filed at any other time would be "off-cycle."

Announcement 2015-19 provides that:

  • Effective immediately, the IRS will no longer accept determination letter applications submitted off-cycle, except for initial plan qualification and qualification upon plan termination

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