Plan Documents & IRS Qualification
2026
- SECURE 2.0 Plan Amendments Due By December 31, 2026
Most private sector defined contribution plans and 403(b) plans must adopt amendments reflecting the SECURE Act and SECURE 2.0 Act (and the CARES Act, if needed and not yet adopted) by December 31…
2025
- ERISA Corrections Beyond EPCRS – Recording Now Available
We recently hosted a Lunch & Learn webinar on a topic that is both nuanced and crucial for retirement plan professionals: ERISA corrections outside the guidance of the IRS’s Employee Plans Compliance…
2020
- Secure Act Makes Significant Changes to the Law Affecting Qualified Retirement Plans
The SECURE Act, signed into law on Dec. 20, 2019, includes a lot of tweaks to retirement law, including many that directly impact qualified retirement plans, as well as others that indirectly impact…
2019
- IRS Issues Final Hardship Regulations
The IRS has issued final regulations updating the section 401(k) and (m) regulations to reflect numerous statutory changes to the hardship distribution provisions under the Code. Summary of Statutory…
- IRS Expands Determination Letter Program to Merged Plans and Statutory Hybrid Plans
The IRS has issued Rev. Proc. 2019-20, expanding its determination letter program to allow submissions by individually designed statutory hybrid plans and merged plans. Previously, the determination…
2018
- Treasury and IRS Issue Final Regulations Amending the Definition of Qualified Matching Contributions and Qualified Nonelective Contributions
The Treasury and IRS have issued final regulations amending the definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs) under regulations regarding…
- Private Letter Ruling Applies Controlled Group Rules to 501(c)(3) Entities
On March 16, 2018 the IRS issued a private letter ruling (PLR 201811009) analyzing and applying the controlled group rules to two related 501(c)(3) entities. The first entity is a Medical Center…
2017
- IRS Issues 2017 “Required Amendments List”
The IRS has issued the 2017 “Required Amendments List” for qualified plans. This is the second list issued since the IRS eliminated the five-year remedial amendment cycle and significantly curtailed…
- IRS Provides Guidance on Calculating the Maximum Loan Amount under IRC § 72(p)(2)(A)
The IRS has issued a memorandum providing guidance to its Employee Plans (EP) Examinations staff to determine, the amount available for a loan under § 72(p)(2) of the Internal Revenue Code (IRC)…
- IRS Proposes Amendments to Definition of QMACs and QNECs – Allowing Broader use of Forfeitures
The IRS has issued proposed regulations that would amend the definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs) applicable to certain qualified…
- IRS Issues Updated Determination Letter Revenue Procedure
The IRS has updated and restated its revenue procedures governing determination letters for various types of employee benefit plans. Rev. Proc. 2017-4 reflects the prior elimination of the five-year…
2016
- IRS Issues 2016 “Required Amendments List”
The IRS has issued its first “Required Amendments List” for qualified plans since it eliminated the five-year remedial amendment cycle, and significantly curtailed the favorable determination letter…
- IRS Updates EPCRS Retirement Plan Correction Procedures
The IRS released Revenue Procedure 2016-51 on September 29, 2016, updating its prior Employee Plans Compliance Resolution System (EPCRS) correction guidance. Significant changes made to the EPCRS…
- IRS Releases 2016-2017 Priority Guidance Plan
The IRS has published its 2016–2017 Priority Guidance Plan containing 281 projects that are priorities for allocation of its resources during the twelve-month period from July 2016 to June 2017.…
- IRS Announces More Changes to its Determination Letter Program
On June 29, 2016, the IRS updated its determination letter program for individually designed tax qualified retirement plans, making a number of significant changes, mostly having to do with (1) when…
- IRS Gives Individually Designed Plans an Additional Year to Convert to Pre-Approved Plan Documents
IRS has announced in Notice 2016-03 that it will extend the deadline for an employer to restate an individually designed plan onto a current pre-approved defined contribution plan document (which is…
2015
- IRS Announces Significant Reduction in Determination Letter Program
On July 21, 2015, the IRS announced changes to the favorable determination letter program for qualified retirement plans. Employers that sponsor individually designed plans should take a close look at…
- IRS Expands Pre-Approved Plan Document Program to Include Cash Balance Plans and ESOPs
On June 8, 2015, the IRS issued Revenue Procedure 2015-36, which announces the IRS expansion of its pre-approved plan program to include cash balance plans and employee stock ownership plans (ESOPs).…