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Recently, the IRS has issued Rev. Proc. 2005-66 (copy attached) which establishes a system of cyclical remedial amendment periods for tax-qualified retirement plans, and also extends the deadline for certain plan amendments. In very general terms, depending upon the last digit of the plan sponsor's EIN number, plans are divided into cycles (A through E), with such cycle determining deadlines for obtaining determination letters. Specific rules will apply if the plan is multiple employer, multi-employer, governmental, or if the plan sponsor has been involved with a merger or acquisition/disposition.

Some plans will have to submit their determination letter requests by as soon as January 31, 2007, under this new approach. Accordingly, it is imperative that you check with your advisors to be sure that you know and understand filings deadlines applicable to your specific plan.

 

 

    

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