Five-year Remedial Amendment Period to End for Employee Plans Determination Letters

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Five-year Remedial Amendment Period to End for Employee Plans Determination Letters

Posted by Kim Chen on July 22nd, 2016

Last July, the IRS described its intent to eliminate, as of 1/1/17, the staggered five-year determination letter remedial amendment cycles for individually designed retirement plans and limit the scope of the program (see Ann. 2015-19, 2015-32 IRB 157 ). Following up on that announcement, the IRS recently made clarifying changes and modifications to the six-year remedial amendment period for preapproved qualified plans and extended, to 4/30/17, the time to adopt a newly approved preapproved defined contribution plan and file for a determination letter for certain adopters for the second six-year remedial amendment cycle. The IRS will delay, until 8/1/17, the beginning of the 12-month submission period for the submission of preapproved defined contribution plans for opinion or advisory letters during the third six-year remedial amendment cycle. Rev. Proc. 2016-37, 2016-29 IRB .