More Time to Submit Certain On-cycle Applications to the IRS

June 30, 2015 is the new 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 IRS said so in IRS Announcement 2014-41, which it issued on Dec. 5. The announcement also provides a two day extension (from Jan. 31, 2015, to Feb. 2, 2015) for Cycle D on-cycle submissions (primarily individually designed plans, including multiemployer plans). 

Pre-Approved Plan Extension

The extension applies to the following:

• pre-approved DB mass submitter lead and specimen plans;
• word-for-word identical plans;
• master and prototype minor modifier placeholder applications; and
• DB non-mass submitter lead and specimen plans.

Under Rev. Proc. 2007-44 and Rev. Proc. 2011-49, as modified by Announcement 2014-4, the submission period for these applications is scheduled to expire on Feb. 2, 2015. This extension applies to all on-cycle pre-approved DB plan submissions.

The IRS also said that it expects to expand the preapproved program to include DB plans containing cash balance features and defined contribution plans containing employee stock ownership plan features. And the IRS is developing tools to help plan sponsors draft these plans; the IRS will make them available before June 30, 2015.

Cycle D Extension

The extension from Jan. 31, 2015, to Feb. 2, 2015, applies to Cycle D filers reviewed for qualification items based on the 2013 Cumulative List of Changes in Plan Qualification Requirements contained in Notice 2013-84.