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Restatement Period for Pre-approved DC Plans Opens May 1

Defined contribution plans that were rewritten between May 1, 2008 and April 30, 2010 and that the IRS pre-approved need to be restated with the IRS. The six-year restatement period begins May 1, 2014 and ends April 30, 2016. The IRS issued a reminder in Announcement 2014-16.

Employers using pre-approved plan documents to restate a plan are required to adopt the plan document by April 30, 2016. Between May 1, 2014 and April 30, 2016, the IRS will accept applications for individual determination letters from employers seeking IRS approval of the documents. The IRS announced these requirements in Internal Revenue Bulletin 2014-17. Additionally, the IRS has made available a list of pre-approved plans.