IRS Implements Changes to Employee Plans Determination Letter Program in Revenue Procedure 2015-6 | Practical Law

IRS Implements Changes to Employee Plans Determination Letter Program in Revenue Procedure 2015-6 | Practical Law

The Internal Revenue Service (IRS) issued Revenue Procedures 2015-6 and 2015-8, updating the employee plans determination letter program and user fees.

IRS Implements Changes to Employee Plans Determination Letter Program in Revenue Procedure 2015-6

by Practical Law Employee Benefits & Executive Compensation
Published on 06 Jan 2015 • USA (National/Federal)
The Internal Revenue Service (IRS) issued Revenue Procedures 2015-6 and 2015-8, updating the employee plans determination letter program and user fees.
On January 2, 2015, the IRS issued Internal Revenue Bulletin 2015-1, which includes Revenue Procedures 2015-6 and 2015-8. Revenue Procedure 2015-6 is a general update of Revenue Procedure 2014-6 and includes some minor changes to the employee plans determination letter program. Specifically, the determination letter program is modified to:
  • Add a summary of the new procedures for processing incomplete applications.
  • Change the address for determination letter requests.
  • Eliminate the process for determining the existence of an employer/employee relationship.
  • Encourage the inclusion of a new Reference List in determination letter applications.
  • Provide that the following requests will be handled by the Office of Associate Chief Counsel (Tax Exempt and Government Entities):
    • minimum funding waiver and determination letter requests (when requesting a waiver of the minimum funding requirement); and
    • technical advice requests.
Revenue Procedure 2015-6 is effective February 1, 2015.
The IRS also issued Revenue Procedure 2015-8, which makes companion changes to the IRS user fee program. The fee amounts remain generally unchanged from 2014.