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IRS Eliminates 5-Year Determination Letter Remedial Amendment Cycles for Individually Designed Plans
Findley [Guidance Overview] July 23, 2015
"Sponsors will need to: [1] keep their eyes on future remedial amendment period guidance; [2] be diligent in properly amending their plans in a timely manner, both for required amendments and discretionary amendments, to preserve the tax-qualified status of their plans; and [3] take into account the IRS's stated intent to extend the remedial amendment period for individually designed plans to a date no earlier than December 31, 2017 and completely (and timely) review their documents for compliance to make sure plan amendments are adopted prior to the end of the period."
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