Compliance January 16, 2007

IRS: Cycle A Moratorium Plans to be Submitted by End of the Month

January 16, 2007 (PLANSPONSOR.com) - Cash balance moratorium plans considered by the Internal Revenue Service (IRS) as being in Cycle A according to a 2005 revenue procedure have to be submitted for determination letters by January 31, 2007, the IRS said Tuesday.
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That follow-up piece of regulatory guidance came in a special edition of theEmployee Plans Newsthat supplements Rev. Proc.  2005-66 .

Tuesday’s notice follows the recent publication of  Notice 2007-6 , released on December 21, 2006, which revealed that the IRS was beginning to process determination letter cases in cash balance conversions (See  IRS Opens Floodgates on Cash Balance Conversion Letter Requests ).

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The Cycle A determination letter application will be reviewed at the same time and by the same person that is assigned the cash balance moratorium plan, according to the regulators. When submitting a Cycle A application, officials said it would be “helpful” if plan sponsors indicate in the cover letter that the plan has been subject to the moratorium on cash balance plans, the IRS said.

Regulators said Tuesday that the “expeditious” issuance of determination letters for cash balance moratorium plans, including Cycle A submissions, is a “high priority.”

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