Fielding Mellish Posted August 30, 2016 Posted August 30, 2016 Money purchase plan Trustees want to convert to a profit sharing plan. No other significant changes. Really want to do it so they don't have to credit participant accounts if there's a delinquent employer. Also may want to allow for hardship distributions. Anyway, I know that a 204(h) notice must be timely distributed and that the MPPP assets have to keep their MPPP character (so there has to be separate accounting). But the biggest question I have is, does the "new" plan have to file for a determination letter, especially considering the new determination letter rules? Thoughts? Thanks. You cannot bash in the head of an American citizen without written permission from the State Department.
Belgarath Posted August 30, 2016 Posted August 30, 2016 Nope. And most pre-approved plans will have appropriate language or elections to preserve prior Money Purchase characteristics when required. (This was also true prior to the new IRS determination letter rules).
Fielding Mellish Posted August 30, 2016 Author Posted August 30, 2016 I didn't think it would be necessary (and really hoped it wouldn't be). Now, these are individually designed plans, if that makes a difference. Though I doubt it. I just wasn't sure if this would be considered a totally new plan that would need a DL. You cannot bash in the head of an American citizen without written permission from the State Department.
QDROphile Posted September 1, 2016 Posted September 1, 2016 No plan is required to have a determination letter. The issue now is the ability to get one to get comfort on substantial provision changes.
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