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ARTICLE · 13 OCTOBER 2022

Save It For A Rainy Day Part 2: IRS Announces Additional Plan Amendment Extensions

McDermott Will & Emery
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Previously, amendments for these CARES Act and Disaster Act provisions would have been required by the end of the 2022 plan year.

United StatesEmployment and HR
Teal N. Trujillo
Teal N. Trujillo
Diane M. Morgenthaler
Diane M. Morgenthaler
Patrick Ryan
Patrick Ryan

On September 26, 2022, the Internal Revenue Service (IRS) extended the amendment deadline for non-governmental qualified retirement plans, plans covered under Section 403(b) of the Internal Revenue Code (Code) and individual retirement accounts (IRAs). The extensions included many of the amendment deadlines under the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the Bipartisan American Miners Act of 2019 (Miners Act), and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). See our prior On the Subject about this earlier extension. Missing from this earlier IRS extension was a postponement of deadlines relating to certain CARES Act provisions, in particular those related to COVID-related distributions and loan relief, as well as deadlines relating to disaster-related loans or distributions under the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Disaster Act).

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