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Integral amendments named for hardship distributions

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Tax Hot Topics newsletterThe IRS issued Rev. Proc. 2020-9 to clarify which amendments are treated as integral to a plan provision that fails to satisfy the requirements for qualified retirement plans under the Internal Revenue Code because of changes made by final regulations regarding hardship distributions of elective deferrals. The required plan amendments for hardship distributions are also listed in the 2019 Required Amendments (RA) List for qualified retirement plans issued in Notice 2019-64.

The revenue procedure also extends the deadline, applicable to pre-approved plans, for adopting an interim amendment with respect to the required amendments and all amendments that are integral to those required amendments. The deadline is extended to Dec. 31, 2021.

Contacts:
Jeff Martin
Partner
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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