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IRS Publishes 2007 Cumulative List of Plan Qualification Requirements for Cycle C Plans

    Client Alerts
  • December 14, 2007

The IRS recently released its annual cumulative list of statutory, regulatory and guidance changes that plan sponsors are required to take into account when submitting applications for determination letters for plans with Cycle C remedial amendment periods beginning on February 1, 2008.  In general, a qualified plan is in Cycle C if the last digit of the plan sponsor’s EIN is 3 or 8.  This new guidance reflects a number of changes, including some made by the Pension Protection Act of 2006 (the “PPA”).  Cycle C plan sponsors may include these PPA provisions in their plans, but the IRS will not consider the PPA provisions, any guidance published or statutes enacted after October 1, 2007, or qualification requirements first effective in 2009 or later in issuing determination letters to Cycle C plans.  However, the new cumulative list clearly states that in order to remain qualified, a plan must comply with all relevant qualification requirements, not just those in the list.