UPDATE – Disapproving the Approval Process: IRS Provides Additional Guidance on the Curtailment of the Determination Letter Program

February 05, 2016

The Internal Revenue Service (the “IRS”) recently released Notice 2016-03, which provides additional details for plan sponsors on the curtailment of the determination letter process for individually designed tax-qualified retirement plans in the U.S. In Announcement 2015-19, the IRS previously indicated that effective January 1, 2017 the IRS would be eliminating the staggered five-year determination letter remedial amendment cycles for individually designed plans and would be limiting the scope of the determination letter program for individually designed plans. We have previously summarized Announcement 2015-19 here.

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