IRS Issues 2015 List of Plan Qualification Changes

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By Kristen Ricaurte Knebel

Dec. 14 — The IRS issued guidance that includes 2015 cumulative list of changes in plan qualification requirements to be used with the determination letter program for individually designed plans eligible for Cycle A.

The Internal Revenue Service will start accepting determination letter applications for Cycle A individually designed plans beginning Feb. 1, the agency said in Notice 2015-84, issued Dec. 14. The list informs plan sponsors of the issues the agency has specifically identified for review in determining whether a plan filing in Cycle A has been properly updated, the IRS said.

The 12–month submission period for plans in Cycle A will end Jan. 31, 2017, the IRS said.

This will mark the final cycle before the IRS generally stops issuing determination letters for individually designed plans that aren't applying for initial qualification or termination. The IRS announced in July that it would be downsizing its determination letter program, citing a need to focus limited resources.

The plans using the cumulative list primarily will be single-employer, individually designed defined contribution and defined benefit plans, the IRS said. Generally, an individually designed plan is in Cycle A if the last digit of the employer identification number of the plan sponsor is 1 or 6.

The IRS said the 2015 cumulative list reflects changes under a variety of laws, including the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, the Consolidated and Further Continuing Appropriations Act, 2015, the Cooperative and Small Employer Charity Pension Flexibility Act and the Pension Protection Act of 2006.

Application Deadlines

When it reviews Cycle A applications for determination letters, the IRS said that, for tax qualification purposes, it generally will not look for plan amendments related to guidance issued after Oct. 1, 2015; statutes enacted after Oct. 1, 2015; qualification requirements that will become effective in 2017 or later; or statutory provisions that will become effective in 2016 for which there is no guidance listed in Notice 2015-84.

To retain their tax-qualified status, however, plans must comply with all relevant tax-qualification requirements, not just the ones included on the 2015 cumulative list, the IRS said.

The general deadline for adopting interim or discretionary amendments appears separately in Section 5.05 of Revenue Procedure 2007-44, the notice said.

Notice 2015-84 is set to appear in Internal Revenue Bulletin 2015-52, dated Dec. 28.

To contact the reporter on this story: Kristen Ricaurte Knebel in Washington at

To contact the editor responsible for this story: Phil Kushin at

A copy of Notice 2015-84 is at


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