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BenefitsLink Retirement Plans Newsletter

Supplement to
January 23, 2014
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BULLETIN

Supplement to January 23, 2014

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[Official Guidance]

Text of IRS Announcement 2014-4: Extension of Jan. 31 Deadline for DB Plan Advisory or Opinion Letters, Also for Certain Cycle C Individually Designed DB Plans (PDF)
"This announcement extends to February 2, 2015, the deadline to submit on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans for the plans' second six-year remedial amendment cycle. This extension applies to defined benefit mass submitter lead and specimen plans, word-for-word identical plans, master and prototype minor modifier placeholder applications, and non-mass submitter defined benefit plans. Under Rev. Proc. 2007-44 ... and Rev. Proc. 2011-49 ... the submission period for these applications [had been] scheduled to expire on January 31, 2014.... In order to preserve (or, in the case of a new plan, obtain) reliance on the terms of their plans, sponsors of individually designed plans who intend to adopt a pre-approved defined benefit plan document in the future may, before the end of their applicable individually designed on-cycle deadline, complete Form 8905, Certification of Intent to Adopt a Pre-approved Plan, in lieu of submitting an application for an individually designed determination letter. The deadline for individually designed Cycle C filers to complete the Form 8905 or apply for a determination letter as an individually designed plan would normally be January 31, 2014. However, pursuant to this announcement, sponsors of individually designed Cycle C plans that do not intend to file a determination letter as an individually designed plan but intend to adopt a pre-approved defined benefit plan document will have until March 31, 2014 to complete Form 8905." (Internal Revenue Service)  

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