On February 8, 2023, the IRS released Announcement 2023-6, indicating that they intend to issue opinion letters for pre-approved defined benefit plans that were amended based on the 2020 plan qualification requirements changes and were filed with the third six-year remedial amendment cycle. The IRS expects to issue the opinion letters on and after February 28, 2023.
Beginning in 2016, the IRS implemented a staggered remedial amendment process for pre-approved plans by creating separate six-year remedial amendment cycles. Originally, the third cycle was set to end on January 31, 2025. This announcement extends the third six-year remedial amendment cycle to March 31, 2025. As such, employer plan sponsors that would like to maintain their pre-approved defined benefit plan for the third six-year remedial amendment cycle will have from April 1, 2023, to March 31, 2025, to submit applications for individual determination letters. The IRS provided additional guidance on this update in Revenue Procedure 2023-4.
Defined benefit plan sponsors should be aware of this guidance and work with their service providers in adopting their plan documents.
Announcement 2023-6 »
PPI Benefit Solutions does not provide legal or tax advice. Compliance, regulatory and related content is for general informational purposes and is not guaranteed to be accurate or complete. You should consult an attorney or tax professional regarding the application or potential implications of laws, regulations or policies to your specific circumstances.
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