This is a pre-approved plan that meets IRS requirements.
When the IRS ended its determination letter program, it said it anticipates making exceptions based on program capacity to work on additional applications, and the need for rulings in certain areas.
Plan sponsors who have already submitted an Application for Determination for Terminating Plan in 2018 will receive a refund of $700.
The agency also issued information about how to obtain or re-establish an employer identification number (EIN) for a retirement plan trust.
The House GOP majority adopted a unified version of the Tax Cuts and Jobs Act Tuesday afternoon; they may have to repeat the process one more time.
IRS compliance questions have been removed from the form.
Following the earliest stages of debate, both the House and the Senate seem to have backed away from major changes to deferred compensation arrangements, as well as from other retirement-industry focused proposals.
The agency also issued a reminder that a certain amount of flexible spending account assets can be rolled over to the following year.
The tables are to be used for determining contributions to DB plans and permitted disparity in DC plan contributions.
Among other changes of note for plan sponsors, the proposal “applies a single aggregate limit to contributions for an employee in a governmental section 457(b) plan and elective deferrals for the same employee under a section 401(k) plan or a 403(b) plan of the same employer.”
The memo lists actions plan sponsors should take to locate missing participants in order not to be challenged on violating RMD rules.
The GOP tax reform proposal leaves 401(k) deferrals alone, but there are other significant reforms in the package that would change the treatment of hardship withdrawals and in-service distributions for DC, DB and 457 plans, among others.
The agency has relaxed loan and hardship distribution rules.
Among its list for retirement plans are projects for which guidance has been long-awaited from the agencies.
In response to a private letter ruling from the IRS, ICMA-RC will provide its public-sector clients with a model 457(b) plan document incorporating auto enrollment based on the plan approved by the IRS.
IRS says missed repayments can be addressed in the following quarter or that participants can refinance a loan, but that it will still be due on the original due date.
Following the IRS' curtailment the determination letter program for retirement plan sponsors, McDermott Will & Emery is releasing an opinion letter and operational review program for individually designed plans.
Plan sponsors will have a number of new compliance checks to keep in mind.
The list of regulatory and legislative challenges affecting employers and their retirement plan consultants can seem endless, and when linked to the increasing litigation from the plaintiffs’ bar, it can seem impossible to reach a point of certainty.