Revised IRS Letter Procedures Eliminate “Working Copy” Submissions of Plan Documents

The IRS recently updated its procedures for issuing determination letters on the qualified status of retirement plans. In Revenue Procedure 2013-6, the IRS eliminated the use and submission of a “working copy” of the plan document as part of the requalification process.

Prior to Revenue Procedure 2013-6, plans were permitted to submit an unsigned working copy of the plan in a restated format. Under the new IRS’s determination letter procedures, individually designed plans must be restated when they are submitted for a determination letter. As in the past, the submission must also include copies of all amendments adopted since the most recent determination letter.
For information on the requalification process, please contact your Trust Fund Counsel.

By Patricia Davis

Legal Developments