Determination Letter

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Plan sponsors of Code Section 403(b) tax-sheltered annuity plans (“403(b) plans”) that have not already done so may want to consider applying for an IRS determination letter or planning and budgeting for the process next year if they are not yet eligible.

In June, the IRS determination letter program became available to a second group…

On October 21st, the IRS announced changes to its qualified plan determination letter program. Most notably, the program has been expanded to include section 403(b) tax-sheltered annuity plans (“403(b) plans”). Although 403(b) plans are similar to tax-qualified defined contribution plans (“401(a) plans”), they are subject to unique rules, and, until now, the IRS…

On May 1, 2019, the IRS released Revenue Procedure 2019-20 which provides for a limited-scope expansion of its determination letter program for individually designed plans. Beginning on September 1, 2019, the IRS will accept determination letter applications submitted for the following types of plans:

  • Statutory hybrid plans (e.g., cash balance or pension equity plans). Applications

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The IRS has informally stated that it is intending to make some significant changes to the Determination Letter program, and is even considering eliminating the program for individually designed retirement plans (other than perhaps initial and final determination letters).  The agency apparently is looking to streamline its operations and focus its resources on other areas.  …

Posted in IRS