Revenue Procedure 2005-66 sets out a staggered remedial amendment period in the timing of plan submissions and takes into consideration several announcements and “white papers” on the future of the employer plan determinations letter program (see IRS Asks for Comments on Proposed Staggered Remedial Cycle for Qualified Plans ).
The IRS also announced the annual publication of a Cumulative List of Changes in Plan Qualification Requirements, which it said are intended to identify, on a year-by-year basis, all changes in the qualification requirements resulting from changes in statutes, or from regulations or other guidance published in the Internal Revenue Bulletin that are required to be taken into account in the written plan document. The target date for publication of the Cumulative List is mid-November of each year, the IRS said.
The IRS also described four plan amendment scenarios and described how they would be best and most timely handled.
The new IRS document is at www.irs.gov/pub/irs-drop/rp-05-66.pdf