July 31 Deadline for Certain Pre-Approved Defined Benefit Plan Actions is Approaching

In March, the IRS extended the deadlines for pre-approved defined benefit plan actions for employers due to the Coronavirus pandemic.

tax advisorsThe IRS extended the following deadlines to July 31, 2020:

  1. The April 30, 2020 deadline for employers to adopt a pre-approved defined benefit plan and to submit a determination letter application (if eligible) under the second six-year remedial amendment cycle
  2. The April 30, 2020 end of the second six-year remedial amendment cycle for pre-approved defined benefit plans

IRS also provided that an employer that adopts, by July 31, 2020, a pre-approved defined benefit plan that was approved based on the 2012 Cumulative List, will be considered to have timely adopted the plan within the second six-year remedial amendment cycle. The remedial amendment period for disqualifying provisions described in Rev Proc 2016-37, Sec. 15.03, is also extended to the end of the second six-year remedial amendment cycle.

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