The new Qualified Plan Compliance Program (QPC) from Trucker Huss aims to “fill the void left by the Internal Revenue Service’s recent curtailment of the determination letter program for individually designed qualified retirement plans.”
As the firm explains, effective January 1, 2017, the IRS has limited its determination letter program to initial determinations for new plans and final determinations for terminating plans. “As a result, plan sponsors are no longer able to obtain ongoing written confirmation from the IRS that their plan document continues to meet the tax-qualification requirements of the Internal Revenue Code,” Trucker Huss warns. “Plan sponsors have relied on the IRS determination letter program to facilitate the development of effective internal controls and proper plan operations, and to ensure plan document compliance and consistent monitoring.”
IRS determination letters also provide evidence of qualified plan status, which is crucial to many aspects of plan administration, the firm suggests.
“As the law changes, and as plan documents have to be amended, plan sponsors will no longer be able to rely on their existing IRS determination letters,” the firm explains. “QPCP gives plan sponsors continued confidence that the form of their qualified plan continues to meet the tax- qualification rules of the Code, thus providing stability in administration.”
QPCP provides plan sponsors with a written opinion of counsel that their plan document, as amended after the date of their last IRS determination letter, continues to maintain its tax-qualified status as to form. The QPCP opinion letters will cover required amendments based on updates to the Code’s qualification and transactions.
In addition to an opinion letter, plan sponsors may selectively include the following existing Trucker Huss services under QPCP: reviews of required compliance testing; controlled group/affiliated service group opinions; and customizable operational compliance reviews. QPCP services are available to all types of qualified retirement plans, both defined benefit and defined contribution plans.
For more information, visit www.truckerhuss.com.