2019 Required Amendments List released

Tax Hot Topics newsletterThe IRS recently issued Notice 2019-64 to provide the 2019 Required Amendments (RA) List for qualified retirement plans.

In connection with the elimination of the five-year staggered remedial amendment cycles effective Jan. 1, 2017 (see Rev. Proc. 2016-37), the IRS changed the timing rules for adopting amendments to existing individually designed plans, particularly for required amendments. The deadline for required amendments is now based on the RA List, which is published annually by the IRS.

If an item appears on the RA List for a particular year, the plan sponsor must adopt any amendments needed to conform to the item no later than the end of the second calendar year beginning after the item first appears on the list (this timing rule also applies to non-calendar year plans). For example, an amendment required by the 2018 RA List generally must be adopted by the end of the 2020 calendar year (regardless of the plan year).

The 2019 RA List contains two items in response to final regulations for hardship distributions and for certain collectively bargained cash balance/hybrid defined benefit plans.

Jeff Martin
Washington National Tax Office
T +1 202 521 1526

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

James Sanchez
Senior Associate
Washington National Tax Office
T +1 202 861 4107

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