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Benefits in General

[Official Guidance]

Text of IRS Notice 2020-35: Relief with Respect to Deadlines Applicable to Employment Taxes, Employee Benefits, and Exempt Organizations Affected by the Ongoing Coronavirus Disease 2019 Pandemic (PDF)

"[T]he revised deadline for an Affected Taxpayer to perform a Time-Sensitive Action ... is July 15, 2020, unless a different revised deadline is specified ...

"The Time-Sensitive Actions [include] ...

  • Application for a funding waiver under section 412(c) for a defined benefit pension plan that is not a multiemployer plan....
  • With respect to a multiemployer defined benefit pension plan, actions due to be performed on or before the dates described in: 
    • Section 432(b)(3) for the certification of funded status and the notice to interested parties of that certification.
    • Sections 432(c)(1) and 432(e)(1) for the adoption of, and the notification to the bargaining parties of the schedules under, a funding improvement plan or rehabilitation plan.
    • Sections 432(c)(6) and 432(e)(3) for the annual update of a funding improvement plan and its contribution schedules, or rehabilitation plan and its contribution schedules, and the filing of those updates with the Form 5500 annual return....
  •     Filing of Form 5330 and payment of the associated excise taxes....
  • With respect to the remedial amendment period and plan amendment rules for section 403(b) plans described in Rev. Proc. 2017-18 and Rev. Proc. 2019-39, actions that are otherwise required to be performed on or before March 31, 2020, with respect to form defects or plan amendments. The deadline for those actions is postponed to June 30, 2020 ...
  • With respect to pre-approved defined benefit plans, the deadline for the following actions is postponed until July 31, 2020:
    • Adoption of a pre-approved defined benefit plan that was approved based on the 2012 Cumulative List; 
    • Submission of a determination letter application under the second six-year remedial amendment cycle; and
    • Actions that are otherwise required to be performed with respect to disqualifying provisions during the remedial amendment period that would otherwise end on April 30, 2020....
  • With respect to a compliance statement issued under VCP, implementation of all corrective actions, including adoption of corrective amendments, required by the compliance statement....
  • Request for approval of a substitute mortality table in accordance with section 430(h)(3)(C)....
  • With respect to the Form 5498, IRA Contribution Information, Form 5498-ESA, Coverdell ESA Contribution Information, and the Form 5498-SA, HSA, Archer MSA, or Medicare Advantage MSA Information, the due date for filing and furnishing the forms is postponed to August 31, 2020."

Internal Revenue Service [IRS], Inc.
1298 Minnesota Avenue, Suite H
Winter Park, Florida 32789
(407) 644-4146

Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager

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BenefitsLink Retirement Plans Newsletter, ISSN no. 1536-9587. Copyright 2020, Inc. All materials contained in this newsletter are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

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