IRS Announcement 2014-41 Extends Deadline to Submit Opinion and Advisory Letter Applications for Pre-approved Plans | Practical Law

IRS Announcement 2014-41 Extends Deadline to Submit Opinion and Advisory Letter Applications for Pre-approved Plans | Practical Law

The Internal Revenue Service (IRS) issued Announcement 2014-41, which extends the deadline to submit on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans for the second six-year remedial amendment cycle from February 2, 2015 to June 30, 2015.

IRS Announcement 2014-41 Extends Deadline to Submit Opinion and Advisory Letter Applications for Pre-approved Plans

by Practical Law Employee Benefits & Executive Compensation
Published on 09 Dec 2014 • USA (National/Federal)
The Internal Revenue Service (IRS) issued Announcement 2014-41, which extends the deadline to submit on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans for the second six-year remedial amendment cycle from February 2, 2015 to June 30, 2015.
On December 5, 2014, the IRS issued Announcement 2014-41, which extends to June 30, 2015 the deadline to submit on-cycle applications for opinion and advisory letters for pre-approved defined benefit plans for the second six-year remedial amendment cycle ( (Dec. 6, 2014)). The submission period was previously scheduled to expire on January 31, 2014, and was extended to February 2, 2015 by IRS Announcement 2014-4 (see Legal Update, IRS Announcement 2014-4 Extends Deadline for Pre-approved Plan Opinion and Advisory Letter Applications). The extension applies to:
  • Defined benefit mass submitter lead and specimen plans.
  • Word-for-word identical plans.
  • Master and prototype minor modifier placeholder applications.
  • Non-mass submitter lead and specimen defined benefit plans.
The Announcement explains that:
The Announcement also provides a two day extension (from Saturday, January 31, 2015, to Monday, February 2, 2015) for Cycle D on-cycle submissions. This extension applies to Cycle D filers reviewed for qualification items based on the 2013 Cumulative List of Changes (for information on the 2013 Cumulative List of Changes, see Legal Update, IRS Releases 2013 Cumulative List of Changes in Plan Qualification Requirements).
The IRS plans to:
  • Modify Revenue Procedure 2011-49 to expand the pre-approved program to include defined benefit plans containing cash balance features and defined contribution plans containing employee stock ownership plan (ESOP) features.
  • Develop tools, which will be available before June 30, 2015, to assist plan sponsors in drafting these plans.
For more information on retirement plan determination letters, see: