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IRS to Issue Letters to Master and Prototype, Volume Submitter Plans

The IRS on March 9 said in Announcement 2018-05 that it plans to issue opinion and advisory letters for master and prototype and volume submitter defined benefit plans that were restated for changes in plan qualification requirements listed in Notice 2012-76 and that were filed with the IRS during the submission period for the second remedial amendment cycle. The IRS says that it plans to issue the letters on March 30, 2018 or as soon as possible thereafter.

The IRS says that the period for employer adoption of these plans will end on April 30, 2020. Starting May 1, 2018, and ending April 30, 2020, it will accept applications for individual determination letters from employers that adopt such plans and are otherwise eligible to submit a determination letter request. This announcement also says that the IRS will announce a delayed beginning date for the third six-year remedial amendment cycle in future guidance.

The IRS will publish Announcement 2018-05 on March 26, 2018, in Internal Revenue Bulletin 2018-13.