Opinion, advisory letters for pre-approvals of defined benefits plans

Opinion, advisory letters; defined benefits plans

The IRS today released an advance version of Rev. Proc. 2016-36 that revises IRS procedures for issuing opinion and advisory letters regarding the acceptability under sections 401, 403(a), and 4975(e)(7) of the form of pre-approved plans—master and prototype (M&P) and volume submitter (VS) plans.


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Rev. Proc. 2015-36 [PDF 163 KB] modifies and supersedes Rev. Proc. 2011-49.

Also, Rev. Proc. 2015-36 extends to October 30, 2015, the deadline for submitting on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans for the plans’ second six-year remedial amendment cycle.

The extension to October 30, 2015, applies to pre-approved defined benefit mass submitter lead and specimen plans, word-for-word identical plans, M&P minor modifier placeholder applications, and defined benefit non-mass submitter plans.

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