IRS extends deadline for adoption of newly approved plans


The IRS recently announced (Announcement 2023-6) that it has extended the deadline for qualified defined benefit plans to adopt a newly approved plan for the third six-year remedial amendment cycle under the eligibility rules of Section 19 of Rev. Proc. 2016-37 to March 31, 2025. The old deadline was Jan. 31, 2025.


The announcement further informs adopting employers of a newly approved plan that applications for an individual determination letter — if otherwise eligible — will be accepted from April 1, 2023, to March 31, 2025. 


The IRS also expressed that, on Feb. 28, 2023, or soon thereafter, it intends to issue opinion letters for preapproved defined benefit plans already updated for changes in plan qualification requirements listed in Notice 2020-14 (the “2020 Cumulative List”) and that were filed with the IRS during the third six-year remedial amendment cycle under the remedial amendment cycle system for pre-approved plans established under Rev. Proc. 2016-37.   




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