IRS Asks for Comments on Proposed Staggered Remedial Cycle for Qualified Plans

September 13, 2004 ( - The Internal Revenue Service (IRS) is asking for comment on a proposed plan to establish a system of staggered remedial amendment cycles for qualified retirement plans.

>The result of an ongoing review that seeks to mitigate the periodic fluctuations in workload as a result of legislative change, the proposed plans would create a five-year remedial amendment cycle for individually-designed plans, and a six-year cycle for pre-approved plans.

>These systems would create fixed, regular cycles for the adoption of remedial amendments, as well as the submission of determination opinion, and advisory letters. Essentially, different plans would have different five or six-year cycles, making a more consistent workload for the IRS. Cycles would be assigned according to the taxpayer identification number of the employer who maintained the plan.

>In October of 2003, Carol Gold, Director of Employee Plans at the IRS, suggested at an American Society of Pension Actuaries (ASPA) conference that the IRS was considering the change (See  DL Volumes High, But Within Expectations: IRS ).

>The IRS is inviting comment on the proposed plan, due by January 3, 2005. All comments should be addressed to: CC:PA:LPD:RU (Announcement 2004-71), Room 5203, Internal Revenue Service, POB 7604 Ben Franklin Station, Washington, DC, 20044.