Author Archives: Administrator

IRS Extends DC Opinion/Advisory Deadline to April 2, 2012

It is rare that anything released by the IRS elicits a response of “We celebrate tonight!”, but it happened today with Announcement 2012-3. At 11:31am ET today, Dec. 22, 2011, the IRS extended the deadline to submit defined contribution opinion/advisory … Continue reading

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2011 IRS Cumulative List Provides Year in Review

Nothing provides a Year in Review list for plan documents like the annual IRS Cumulative List. Yesterday, the IRS released Notice 2011-97 containing the 2011 Cumulative List. It’s primary purpose is to provide the guidance which must be included in … Continue reading

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Target Benefit Plans: On the Edge of Extinction

One of the more interesting effects caused by the IRS’ elimination of the National Sponsor category in Rev. Proc. 2011-49 may be the projected elimination of pre-approved target benefit prototype and volume submitter plans. While some of you may be … Continue reading

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Just in Time – The IRS Issues an Extension and a Sample Amendment for Code sec. 436

Just when the mad scramble to adopt last minute Code section 436 amendments was about to begin, the IRS has issued another extension, accompanied by a sample amendment. Notice 2011-96, released Nov. 29, 2011, extends the deadline to adopt an … Continue reading

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Free ERPA CPE from the IRS on Nov. 30, 2011

On Nov. 30, 2011, the IRS is holding a free phone forum on the Self Correction Program (SCP) and the Closing Agreement Program (CAP). It will focus on: (1) current EPCRS issues found in SCP and CAP cases; (2) procedures … Continue reading

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ERPAs and the PTIN Requirement – as Clear as Mud

Today, Nov. 3, 2011, the IRS issued Notice 2011-91 on Certain Enrolled Retirement Plan Agents Not Required to Obtain a PTIN. The notice is a short 2-pages long. It states that the IRS intends to amend Circular 230 to remove … Continue reading

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ESOP/KSOP Determination Letter Backlog Here to Stay (for now)

I was fortunate to attend the IRS phone forum on ESOP determination letters last Friday. The webinar was very good. The IRS addressed a number of outstanding issues, and provided some handy tips. First, the IRS acknowledged that there is … Continue reading

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Free IRS Webinar about ESOP Determination Letters on Oct. 28, 2011

Tomorrow, Oct. 28, 2011, the IRS is holding a free webinar on ESOP determination letter applications from 2pm ET to 3pm ET. Even if you do not handle ESOPs, it is worth taking an hour to attend this webinar because … Continue reading

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IRS Re-Interprets the Form 8717 Determination Letter Fee Exemption

On Oct. 20, 2011, the IRS issued Notice 2011-86, which re-interprets when a plan qualifies for exemption from paying user fees when filing a determination letter application. With the recent IRS increase in user fees for determination letter applications (individually … Continue reading

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DOL Issues New Final Regs on Investment Advice for 401(k)s

Today, Oct. 24, 2011, the IRS issued new Final Regs on Investment Advice to Participants and Beneficiaries in individual account plans, including 401(k) plans. The regulations say they affect plan sponsors, fiduciaries, participants and beneficiaries of participant-directed individual account plans, … Continue reading

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