Prototype to IDP

[britoski]

Client previously adopted a protoptype plan and now has decided to switch to an individually designed plan. Can the client restate onto an IDP by April 30?

[Kevin C]

Was the previously adopted prototype a GUST prototype or an EGTRRA prototype?

Which 5 year IDP restatement cycle are they under?

[Kevin C]

If the prior prototype was a GUST document, I think they will have to adopt an EGTRRA pre-approved document by 4/30/2010 unless they happen to be under IDP Cycle E.

The 4/30/2010 deadline is under the 6 year cycle for pre-approved plans. But, they are not considered a "prior adopter" under Rev. Proc. 2007-44, section 17.02 unless they actually adopt an EGTRRA pre-approved document by 4/30/2010. Since they currently have a prototype, they would not qualify as a new adopter or intended adopter. So, if they do not adopt a pre-approved document by 4/31/2010, they are not eligible for the 6 year cycle. That means they are under the 5 year IDP cycle. Cycle D ended 2/1/2010, so Cycle E is the only IDP EGTRRA cycle currently open.