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EGTRRA Amendment timelines


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Guest money40
Posted

Does anyone know of a "list" of amendments by date required to use as a reference when determining if a terminated plan needs to be restated or to ensure the plan has all "required" amendments prior to the plan termination date?

Thank you,

  • 2 weeks later...
Posted

I'm curious: do practitioners consider a list compiled by a documents provider more helpful than the IRS's Cumulative List?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

For a terminating plan, I would consider the document provider's information more helpful. But, in most cases, I would be more interested in the amendment they provide for terminating plans than a list.

The IRS's 2007 cumulative list does not consider guidance published after 10/1/07 and statutory provisions first effective in 2008 for which there is no guidance on the 2007 cumulative list. However, terminating plans must include all law changes in effect at the time of termination. It is possible that a terminating plan would need to amend for something that is not listed on the most recently published cumulative list.

Peter, is the 2008 cumulative list out yet?

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