About this BlogWelcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.
In our 2017 End of Year Plan Sponsor “To Do” List (Part 4) Qualified Plans, we suggested that sponsors of all qualified retirement plans should be on the lookout for the Internal Revenue Service’s (“IRS”) 2017 Required Amendments List (“RA List”). The IRS recently published Notice 2017-72, which contains the 2017 RA List, https://www.irs.gov/pub/irs-drop/n-17-72.pdf.
Part A of the RA List addresses changes in qualification requirements that require amendments to most plans (or to the types impacted by the change). The 2017 RA List contains two changes in Part A: those required by final regulations regarding cash balance/hybrid plans and those that address benefit restrictions for certain defined benefit plans that are eligible cooperative plans or eligible charity plans described in Section 204 of the Pension Protection Act of 2006, as amended. Read More ›
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In a previous blog, we discussed the IRS’ elimination of its five year staggered determination letter cycle for individually designed plans. The IRS recently provided guidance to help sponsors of individually designed plans keep their plans in compliance with applicable law. Notice 2016-80 contains the first Required Amendments List (the “RA List”) for individually designed qualified retirement plans. In general, the RA List is a list of changes in the plan qualification requirements for changes that became effective in 2016. The list is divided into two parts—(A) changes in qualification requirements that would generally require an amendment to most plans or to most plans of the type affected by the change and (B) changes that the IRS and Treasury anticipate will not require an amendment in most plans, but might require an amendment due to an unusual provision in a particular plan. Read More ›
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