Pension Protection Act Blog

In Announcement 2008-23, released on Friday, the IRS announced that:
1. The EGTRRA defined contribution prototype and volume submitter opinion/advisory letters will be issued March 31, 2008 for many plans. Some plans will have their opinion/advisory letters issued after March 31, 2008.
2. April 30, 2010, is the restatement deadline for plan […]

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Tucked away in Section 6.05 of Rev. Proc. 2008-6 is a requirement that determination letter submissions contain a highlighted or redlined copy of the plan document. It states:

6.05 Except in the case of applications involving master and prototype plans filed on Form 5307 or determination letters for volume submitter plans under section 9.02(2)(d), a […]

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In a few weeks, on January 31st, Cycle B ends and Cycle C begins. Cycle C marks the middle of this great experiment called the EGTRRA remedial amendment cycle restatement period. Like all experiments, charts and tables come in handy. When the IRS issued Rev. Proc. 2007-44 last year, they also updated […]

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Back on September 19th, the IRS issued Announcement 2007-90, announcing that beginning December 18th, 2007, the IRS would temporarily stop accepting applications for determination letters for defined contributions plans filed on Form 5307. Any determination letter application for a defined contribution plan filed on Form 5307 on or after today (December 18th) and before […]

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The IRS published the Fall 2007 Edition of Employee Plan News today. Within this edition, the IRS confirms that the target date for issuing the EGTRRA opinion/advisory letters to pre-approved prototype and volume submitter plans is March 31, 2008.
This date is important because it kicks off the two-year restatement period in Rev. Proc. 2005-66 […]

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Today, the IRS issued Announcement 2007-90. It states that on December 18, 2007, the IRS will temporarily stop accepting applications for determination letters for defined contribution plans that are filed on Form 5307. The Service states that this temporary hiatus is to allow them to prepare to receive EGTRRA applications.
The IRS will process […]

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What happens if you thought a plan was not a Cycle A plan, and so you did not restate it for EGTRRA and did not submit it for a determination letter by January 31, 2007, and then you read Rev. Proc. 2007-44, and realize that the plan is a Cycle A plan, and should have […]

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Today, the IRS published Revenue Procedure 2007-44, which is the long-awaited revision to Rev. Proc. 2005-66. (Hat tip to Benefitslink.com)
For defined benefit pension plan geeks, we are celebrating tonight because the deadline for submitting the plans for opinion/advisory letters was just extended from October 31, 2006, to January 31, 2008. Three more […]

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How often should a plan document be restated? Not an easy question to answer because it can be more often than waiting for the mandatory restatements periodically required by the IRS. A little remembered section of Revenue Procedure 2007-6 requires that plan documents are restated after 4 amendments. The exact language of […]

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