Reopening the Floodgates: IRS Announces Expanded Determination Letter Program

As we previously reported, the Internal Revenue Service (the “Service”) scaled back its determination letter program for individually designed retirement plans effective as of January 1, 2017. In the intervening years, the Service received a multitude of comments requesting the reopening of the program.

Now, the Service has decided to offer a limited expansion of the determination letter program as outlined in Revenue Procedure 2019-20 (the “Revenue Procedure”). In particular, the Revenue Procedure provides that the Service will accept determination letter applications for both individually designed statutory hybrid plans and individually designed merged plans.

Hybrid Plans

The Revenue Procedure indicates that plan sponsors may submit determination letter applications for individually designed statutory hybrid plans during the twelve-month period beginning September 1, 2019 and ending August 31, 2020. Read More ›

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Treasury Department and IRS Publish Final Hybrid Plan Regulations and Announce Extension of Required Amendment Date for Certain Hybrid Plan Provisions

The Treasury Department and the IRS recently issued final regulations (the “2015 Final Regulations”) relating to hybrid retirement plans, including cash balance pension plans.

The 2015 Final Regulations provide anti-cutback relief to allow hybrid plans to be amended to change the interest crediting rate to an interest crediting rate that is a market rate of return as described in the hybrid plan final regulations issued in 2014 (the “2014 Final Regulations”).

The 2015 Final Regulations allow plan sponsors additional time to amend hybrid plans to comply with the 2015 Final Regulations as well as certain provisions of the 2014 Final Regulations.  Read More ›

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