New Determination Letter Process for Tax-Qualified Employee Benefit Plans: Preparing for Massive Changes
Amending Plans in the Absence of Determination Letters, Elimination of the Five-Year Cycle, and ECPRS Transition Guidance
Recording of a 110-minute CPE webinar with Q&A
This course will provide employee benefits professionals and auditors with a critical first look at the new IRS guidelines that virtually eliminate the Determination Letter Program for retirement plans. The panel will also detail the specific changes contained in Rev. Proc. 2016-51, and offer useful guidance in helping plan professionals to prepare for the new rules, effective Jan. 1, 2017.
Outline
- Specific changes to employee benefit plan determination letter program
- Elimination of determination letters for amendments to existing plans
- Elimination of five-year amendment cycle after Jan. 31, 2017
- ECPRS changes in conjunction with scaling-back of determination letter program
- Impact of tax return due dates on plan contribution deadlines
- Additional guidance
Benefits
The panel will discuss these and other critical questions:
- How does the elimination of the five-year amendment cycle under the new regulations impact plan administrators in making amendments to existing plans?
- Under the new rules, what plans may submit determination letter applications?
- For plans covered by current five-year remedial plan Cycle A, what is the deadline for submitting a request for a determination letter?
- What transition steps and provisions has the Service established during the program transition?
- What additional guidance and changes to ECPRS has the Service made to assist plan professionals?
- What is the impact of the change in return due dates on employers who make their plan contributions by the due date?
Faculty
Luke D. Bailey
Partner
Clark Hill
Mr. Bailey specializes in employee benefits law and executive compensation. He has extensive experience in the tax... | Read More
Mr. Bailey specializes in employee benefits law and executive compensation. He has extensive experience in the tax and fiduciary requirements of qualified retirement and other employee benefit and executive compensation plans of both private and public corporations and state and local governments. A significant portion of his practice consists of federal income tax compliance work for sponsors of governmental pension plans under IRC §414(d). His work in the executive compensation area includes the design, drafting, and provision of tax and legal advice concerning stock option plans, nonqualified deferred compensation, severance pay plans and arrangements, and executive employment agreements.
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Susan J. Peirce, CPA, MTax
Principal
Apple Growth Partners
Ms. Peirce leads the firm’s employee benefits audit and specialty services team. In addition to her audit work,... | Read More
Ms. Peirce leads the firm’s employee benefits audit and specialty services team. In addition to her audit work, she provides consulting services to business owners and professionals on tax and accounting strategies, with a special emphasis on benefit plan services. Her expertise includes a focus on qualified retirement plans and related design, compliance, non-discrimination testing, distribution and reporting issues.
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Henry Talavera
Shareholder
Polsinelli
Mr. Talavera has extensive experience representing clients before the IRS and U.S. Department of Labor. His... | Read More
Mr. Talavera has extensive experience representing clients before the IRS and U.S. Department of Labor. His practice encompasses all areas of employee benefits law related to benefit programs and arrangements for employees, directors, and independent contractors. His experience includes guidance relating to public, private, and tax-exempt employers on the design, implementation, and administration of all types of welfare plans and tax-qualified retirement plans, including defined benefit and plans intended to qualify under sections 401(k), 403(b) and 457(b) of the Internal Revenue Code.
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