Benefits and Compensation

IRS to Issue Opinion Letters, Extend Amendment Cycle for Some Restated Preapproved DB Plans

The Internal Revenue Service (IRS) intends to issue opinion and advisory letters for some preapproved defined benefit (DB) pension plans restated for changes in plan qualification requirements, the IRS announced March 9.IRS

The IRS said in Announcement 2018-05 that the letters would be issued for master and prototype (M&P) and volume submitter (VS) plans that were restated as a result of changes listed in Notice 2012-76, and filed with the agency during the submission period for the second 6-year remedial amendment cycle. The IRS indicated it would issue the letters March 30, or as soon after that date as possible.

Extends Cycle

This announcement extends the remedial amendment cycle for affected preapproved DB plans to make the changes in plan qualification that were included in the 2012 Cumulative List.

The agency said the period for employer adoption of these plans now will end on April 30, 2020. Starting May 1, 2018, and ending April 30, 2020, the IRS will take applications for individual determination letters from employers that adopt such plans and are eligible to submit a determination letter request.

In future guidance, the IRS said, it plans to announce a delayed beginning date for the third 6-year remedial amendment cycle, which begins on February 1, 2019.

The IRS published Announcement 2018-05 on March 26, 2018, in Internal Revenue Bulletin 2018-13.

Jane Meacham is the editor of BLR’s retirement plan compliance publications. She has nearly 30 years’ experience as a writer/editor of financial services news.