Cycle A Determination Application Period Open to Controlled Groups

In its latest Employee Plans newsletter, the Internal Revenue Service said Cycle A contains an exception allowing plan sponsors to file a determination application using a controlled group election. Generally, the last digit of the plan sponsor’s EIN determines the five-year remedial amendment cycle for the plan. However, all plan sponsors who are members of a controlled group or affiliated service group may elect Cycle A as their remedial amendment cycle regardless of the last digit of their EIN.  

For a non parent-subsidiary controlled group, the Cycle A election must: 

• be made by all members sponsoring qualified plans; 
• list the names and EINs of all eligible members; 
• contain the original election, copies of any additional elections executed by new members and an updated list with current information on any new determination letter applications; and 
• be made by any new member within one year of joining the controlled group in order for other members to maintain the existing election. 

For a parent-subsidiary controlled group, the Cycle A election must: 

• be made by all members of the controlled or affiliated service group (the parent company may elect for 
• all members); and 
• include the names and EINs of all eligible members.