Betsy L. Luxenberg is an Associate in Holland &
Knight's
Tysons office
Claudia L. Hinsch is a Partner in Holland &
Knight's
Tysons office
HIGHLIGHTS:
- Effective Sept. 1, 2019, the sponsors
of certain retirement plans may submit their plans to the Internal
Revenue Service (IRS) for review of a determination letter
application.
- Revenue Procedure 2019-20 expands the
IRS Determination Letter Program, provides for a limited extension
of the remedial amendment period and includes a special sanction
structure for certain plan failures discovered on review.
The Internal Revenue Service (IRS) published Revenue Procedure 2019-20 on May 1, 2019,
providing for a limited expansion of the determination letter
program with respect to certain individually designed plans. The
IRS will now accept determination letter applications for 1)
individually designed statutory hybrid plans during a 12-month
period beginning Sept. 1, 2019, and ending Aug. 31, 2020, and
