IRS Adjusts Determination Letter Application Cycles

June 13, 2007 ( - The Internal Revenue Service (IRS) has issued Revenue Procedure 2007-44, which modifies plan amendment and determination letter application cycles for plans to accommodate provisions in the Pension Protection Act of 2006 (PPA) including permanency of the Economic Growth Tax Relief and Reconciliation Act (EGTRRA).

Revenue Procedure 2005-66 established a system of cyclical remedial amendment periods for individually designed (every five years) and pre-approved plans (every six years). The purpose of this was to enable plans to apply for new determination letters only once every five or six years (See  IRS Lays Out Staggered Remedial Amendment Schedule ).

The new revenue procedure adjusts those cycles for plans to accommodate new deadlines established for adopting certain provisions of the PPA, including making permanent EGTRRA provisions. The new revenue procedure intends to decrease the necessity for plans to apply for new determination letters more often than their five- or six-year cycle.

The document has a new table of plan cycles for remedial amendment periods. In addition, the notice includes a cumulative list of plan qualification requirements.

Plan qualification requirements were updated earlier this year to reflect PPA and EGTRRA provisions (See IRS Adds EGTRRA and PPA Provisions to Qualification Requirements ).

Revenue Procedure 2007-44 can be viewed here .