IRS Reviews Deadline for Section 436 Options as Year-End Approaches

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IRS is considering extending a year-end deadline for sponsors of single-employer defined benefit plans to amend their plans to reflect funding-based restrictions on benefits and benefit accruals under tax code Section 436, an IRS official says. “We are seriously considering extending the deadline beyond Dec. 31, 2010,” Michael Spaid says. Spaid adds that an extension of the amendment deadline is by no means certain, but officials are mindful of the fact that IRS has issued no model plan language or substantial guidance since it issued final regulations under Section 436 in October 2009.