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Remedial amendment deadlines extended

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Tax Hot Topics newsletterThe IRS issued a release on its website on March 27 announcing the extension of certain remedial amendment deadlines for Section 403(b) plans and pre-approved defined benefit plans due to COVID-19.

The last day of the initial remedial amendment period for Section 403(b) plans is extended from March 31 to June 30, 2020. Plan sponsors now have until the extended deadline to update their pre-approved and individually designed 403(b) plan documents.

The following deadlines for pre-approved defined benefit plans have been extended to July 31, 2020:
  • The April 30, 2020, deadline for employers to adopt a pre-approved defined benefit plan and submit a determination letter application under the second six-year remedial amendment cycle
  • The April 30, 2020, end of the second six-year remedial amendment cycle for pre-approved defined benefit plans

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. Furthermore, the third six-year remedial amendment cycle for pre-approved defined benefit plans will now begin on Aug. 1, 2020, but it will still end on Jan. 31, 2025.

Contacts:
Jeff Martin
Partner, Washington National Tax Office
T +1 202 521 1526

Keith Mong
Manager
Washington National Tax Office
T +1 202 521 1554

Jason Seo
Senior Associate
Washington National Tax Office
T +1 202 861 4107


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