Category Archives: amendments

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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8th Circuit Decides Signed Letter to Participants Plus SPD Equals Amendment

In Halbach v. Great-West Life & Annuity, No. 07-3865/07-3867 (CA8 April 13, 2009), the 8th Circuit Court of Appeals recently addressed what constitutes a valid amendment to an employee welfare benefit plan. In 2004, Great-West provided a package of medical … Continue reading

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Massive Fines for Failure to Timely Amendment

VCP fine for not timely adopting a 401(a)(31)(B) amendment: $375 Audit CAP fine for not timely adopting a 401(a)(31)(B) amendment: $3,000 Audit fine for not timely adopting a 401(a)(31)(B) amendment: $45,000 Timely amending your plan: Priceless Recently, it seems that … Continue reading

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