Amendment of plans for TRA '86

[Guest Lawrence_Groves]

For an IRS submission, the IRS agent is telling us that the plan submitted was not timely amended for the Taxpayer Relief Act of 1986. When was the amendment to be signed to comply with TRA '86? I know the year was 1994 but I need a specific cite.

[Guest mkimball]

I believe the deadline for adopting the amended plan was 12/31/94, but the extended submission date for a determination letter request was 3/31/95.

[Guest merlin]

Announcement 94-136 granted a 3-month extension for all plans whose RAP would otherwise have ended 12/31/94, 1/31/95, 2/28/95, or 3/31/95. In addition, Rev. Proc. 95-12 granted an additional 6 months after receipt of a favorable opinion,notification or advisory letter for certain regional prototype, M&P, and Volume Submitter plans. For example, our db regional prototypes got the Opinion Letter dated 12/30/94, so our db clients had until 6/30/95 to amend for TRA86. I still get the same question on GUST submissions, and audits as well.