Changes to the Determination Letter Program

[Guest Pensions in Paradise]

Do you like the thought of working on plan restatements every day for the rest of your life? If not, then you should let the IRS know how you feel. Because, in a nutshell, the IRS' current idea would mean that every year you would have to restate 1/5 of your plans.

The IRS is serious about implementing some type of change. Therefore, it is imperative that the pension community let the IRS know how it feels.

white_paper2.pdf

[g8r]

I haven't decided if I'm in favor of status quo or the staggered remedial amendment period.

While the thought of restating 1/5 of all plans each year isn't wonderful, the alternative is crunch time trying to get all plans restated at once. For many people that has been a tremendous burden. By doing 1/5 each year, you might be able to get a "groove in your swing" and the process might be smoother and not tie up as much of your resources.

The idea of staggered dates doesn't alarm me. Then again, I think there are so many details that need to be worked out on this that I'm not sure it's really viable.

And, if you don't like the staggered approach, you're probably not wild about the annual amendment approach (to the extent we aren't already in that mode).

[Mike Preston]

I think I like the 1/5 rule, but I agree that there are so many implementation issues that it may never come to pass.