David Powell, Groom Law Group, answers:
Informal conversations with senior IRS national office personnel indicates that it is still expected and has just been delayed due to the usual delays in issuing guidance, and staff being occupied with other guidance. Those personnel have continued to state in speeches that plan documents do not need to be amended for intervening changes in the law such as WRERA and HEART until that guidance indicates. Before that guidance is issued, we can expect in the very near future to see guidance on 403(b) plan terminations. An updated EPCRS revenue procedure covering both 403(b) and 457(b) corrections is also still in the works. So stay tuned.
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