2020 cumulative list for DB plans released

Tax Hot Topics newsletterThe IRS issued Notice 2020-14 providing the 2020 Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Benefit Plans. The list identifies recent changes in requirements for plans that will be considered by the IRS in its review of plan documents for purposes of issuing opinion letters to pre-approved plan providers. Applicable changes include items to update plan benefits to include same-sex couples, permit rollovers from qualified plans to SIMPLE IRAs, implement regulations for statutory hybrid plans, and comply with other miscellaneous provisions. However, the IRS will not consider statutes enacted after Dec. 1, 2019, and therefore, defined benefit plan documents submitted in connection with the qualification requirement changes made by the Setting Every Community Up for Retirement Enhancement Act (SECURE Act) will not be reviewed.

Pre-approved plan providers can use the cumulative list to update their pre-approved defined benefit plans for the third six-year remedial amendment cycle and submit their updated plans to the IRS during the on-cycle submission period, which begins Aug. 1, 2020, and ends July 31, 2021. When the IRS completes its review of the updated pre-approved defined benefit plans submitted during the third cycle, the IRS will announce the period within which adopting employers/sponsors must adopt the updated plans in order to rely on the opinion letters issued to the pre-approved plan providers.

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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