Lori Shannon and Monica Novak from Drinker Biddle and Chris Shankle, a member of the Advisory Committee on Tax Exempt and Government Entities, discussed the revised determination letter program under IRS Revenue Procedure 2016-37 and considerations for sponsors of individually designed qualified plans.
Key topics included:
- When determination letter applications will be accepted by the IRS.
- Changes to the remedial amendment period and plan amendment deadlines.
- IRS new annual Required Amendments List and Operational Compliance List.
- Converting to a pre-approved plan format.
- Action steps for sponsors of individually designed qualified plans.