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

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.