IRS Issues Updated Determination Letter Revenue Procedure

The IRS has updated and restated its revenue procedures governing determination letters for various types of employee benefit plans.

Rev. Proc. 2017-4 reflects the prior elimination of the five-year remedial amendment cycles for individually designed plans and includes other changes made to the determination letter program, including:

  • limited-scope determination letters on partial terminations if an employer is not otherwise eligible to request a determination letter;
  • determination letters on leased employees only if the employer is otherwise eligible to request a determination letter;
  • no determination letters on affiliated service groups; and
  • modified procedures for requesting relief from retroactive revocations of determination letters or letter rulings.

Author: Erwin Kratz

Erwin Kratz practices exclusively in the areas of ERISA and employee benefits law, focusing on tax and regulatory matters relating to qualified and nonqualified deferred compensation and welfare benefits.