irs notice 99-44

[Larry M]

It's a good thing IRS issued notice 99-44 and removed all ambiguities - that is, except at least this one -

for plans which do specifically provide the 415(e) limits (w/o reference to the Code) and which, therefore, must be amended to allow the increase (in those cases where they wish to do so), do we have until the GUST remedial amendment period extension to do so?

That is, must we amend before 1/1/2000 (and before the GUST amendments), or can we wait until the last day of the 2000 plan year?

By implication, Q&A 7 suggest we can pay the higher benefits during the 2000 plan year, IF the plan is so amended by the end of that year.

Is my understanding correct?