New Two-Year Period to Adopt Restated Pre-approved DC Plans
The IRS expects to issue most opinion and advisory letters for the latest round of pre-approved defined contribution plans on March 31, 2014. Employers using pre-approved defined contribution plan documents must adopt plan documents restated for the 2010 Cumulative List by April 30, 2016 (Announcement 2014-16).
Determination letters for pre-approved defined contribution plans
Starting May 1, 2014, and ending April 30, 2016, employers can submit applications for individual determination letters for pre-approved defined contribution plans.
An employer who adopts a master & prototype plan (standardized or non-standardized) may not apply for its own determination letter on Form 5307, Application for Determination for Adopters of Modified Volume Submitter Plans (instructions) – instead, the employer should rely on the letter issued to the plan sponsor.
However, an adopting employer who made limited modifications to its volume submitter plan may apply for a determination letter on Form 5307. If the modifications are extensive, causing the plan to be treated as an individually designed plan, the employer must instead file Form 5300, Application for Determination for Employee Benefit Plan.
See Revenue Procedure 2014-6, sections 8 and 9 for more information on determination letter applications for pre-approved plans.
- FAQs: Changes Relating to Form 5307 and Demos
- Adopting Employers
- Determination, Opinion and Advisory Letters