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.
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.
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