Share

Northwest OH Legal Blog

Tuesday, May 1, 2018

Internal Revenue Service Requests Comments on Expansion of Determination Letter Program for Individually Designed Retirement Plans

The Internal Revenue Service (“IRS”) has asked for comments on whether it should expand the determination letter program for individually designed plans for 2019. Currently, determination letter applications for individually designed tax-qualified retirement plans (including 401(k) plans) may be submitted only for initial plan qualification—i.e., submissions by plans that have never received a determination letter—and for terminating plans. The guidance establishing those rules anticipated that the IRS would annually consider whether to expand the scope of the program; this Notice is the first request for comments on this topic since the current rules were adopted. (Opinion or advisory letters for preapproved plans can still be submitted on a regular six-year remedial amendment cycle.) 

Pursuant to IRS Notice 2018-24, the IRS asks commenters to indicate whether specific types of plans should be allowed to submit determination letter applications during calendar year 2019 in situations other than initial qualification and termination.  Examples of circumstances that might support expanding the program include significant law changes, new approaches to plan design, and the inability of certain types of plans to convert to pre-approved plan documents.  The notice advises that comments should be specific about the issues raised by a particular plan type that would justify determination letter review, such as plan features or designs, or unresolved legal issues raised by that plan type. Comments are due by June 4, 2018.



Archived Posts

2018
2017
December
November
October
September
August
July
June
May
April
March
February
January
2016
December
November
October
September
August
July
June
May
March
February
January
2015
November
October
September
August
July
June
May
April
March
2014
October
September
July
June
May
April
March
February
January
2013


With an office located in Toledo , OH Allotta Farley Co., L.P.A. serves clients throughout northwest OH with various legal matters. Areas of service include Allen County, Ashland County, Auglaize County, Crawford County, Defiance County, Erie County, Fulton County, Hancock County, Hardin County, Henry County, Huron County, Lucas County, Marion County, Mercer County, Morrow County, Ottawa County, Paulding County, Putnam County, Richland County, Sandusky County, Seneca County, Van Wert County, Williams County, Wood County, Wyandot County.

Disclaimer
Hiring an attorney is an important decision which should not be based solely on advertising. The information you obtain at this site is not, nor is it intended to be, legal advice. You should consult an attorney for advice regarding your individual situation. We invite you to contact us and welcome your calls, letters and electronic mail. Contacting us does not create an attorney-client relationship. Please do not send any confidential information to us until such time as an attorney-client relationship has been established.



© 2018 Allotta | Farley Co., L.P.A. | Disclaimer
2222 Centennial Road, Toledo, OH 43617
| Phone: 419.535.0075

Labor Union Representation | Taft–Hartley/Multiemployer Benefit Plans | Unemployment/Appeals | Public Pension Disability Claims | ERISA Disability | Attorneys

Law Firm Website Design by
Zola Creative