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ARTICLE · 19 APRIL 2016

IRS Provides Update On Pending Guidance On The Determination Letter Program

Trucker Huss, APC
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On July 21, 2015, the IRS released Announcement 2015-19, announcing a significant curtailment of the IRS determination letter program for individually designed retirement plans.

United StatesEmployment and HR
Kevin Nolt
Kevin Nolt

On January 4, 2016, the Internal Revenue Service ("IRS") issued Notice 2016-03, which provides that the Department of Treasury ("Treasury") and the IRS will issue guidance in anticipation of the elimination, effective January 1, 2017, of the five-year remedial amendment cycle system for individually designed retirement plans under the IRS determination letter program. As described below, the future guidance will address the following: (1) Cycle A elections by controlled groups, (2) determination letter expiration dates and (3) the extension of deadlines for certain defined contribution pre-approved plans. Plan sponsors may rely on the guidance in Notice 2016-03 until further guidance is issued.

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