Compensation & Benefits Library™ gives you accurate answers and practical guidance to help you design, analyze, compare, administer, and communicate compensation and benefits programs...
By Kristen Ricaurte Knebel
Dec. 14 — The Internal Revenue Service issued guidance Dec. 14 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.
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.
For more information, see Compensation and Benefits Library's Determination Letter Process chapter.
To contact the reporter on this story: Kristen Ricaurte Knebel in Washington at email@example.com
To contact the editor responsible for this story: Phil Kushin at firstname.lastname@example.org
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to email@example.com.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to firstname.lastname@example.org.
Put me on standing order
Notify me when new releases are available (no standing order will be created)