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ARTICLE · 03 AUGUST 2015

IRS Pulls Determination Letter Program, Puts Premium On Plan Assessments By Sponsors

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Effective January 1, 2017, the IRS has announced that, due to limited resources, it is eliminating the existing 5-year determination letter application staggered filing cycles for individually designed plans.

United StatesEmployment and HR
Patricia Anglin
Patricia Anglin
Mitchel C. Pahl
Mitchel C. Pahl
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Effective January 1, 2017, the IRS has announced that, due to limited resources, it is eliminating the existing 5-year determination letter application staggered filing cycles for individually designed plans. Off-cycle filings are eliminated immediately.

Determination letter applications will no longer be accepted for individually designed plans, other than:
  • Plans that have not received an initial determination letter (no matter when adopted) can apply for an initial determination letter.
  • Terminating plans can apply for a determination upon termination.
  • Cycle  E filers (EIN ending in 5 or 0)  can  continue to file through
    January 31, 2016.
  • Cycle A filers (EIN ending in 1 or 6 and Cycle A controlled groups) can file during the last Cycle A, which begins February 1, 2016, through the end of the Cycle on January 31, 2017.

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