IRS Implements Changes to Employee Plans Determination Letter Program in Revenue Procedure 2012-6 | Practical Law

IRS Implements Changes to Employee Plans Determination Letter Program in Revenue Procedure 2012-6 | Practical Law

On January 3, 2012, the IRS issued Revenue Procedures 2012-6 and 2012-8 incorporating changes to the employee plans determination letter program outlined in Announcement 2011-82.

IRS Implements Changes to Employee Plans Determination Letter Program in Revenue Procedure 2012-6

by PLC Employee Benefits & Executive Compensation
Published on 03 Jan 2012 • USA (National/Federal)
The IRS issued Internal Revenue Bulletin 2012-1 on January 3, 2012, including Revenue Procedures 2012-6 and 2012-8. Revenue Procedure 2012-6 is a general update of Revenue Procedure 2011-6 and incorporates changes to the employee plans determination letter program outlined in Announcement 2011-82 (see Legal Update, IRS Issues Announcement 2011-82 Outlining Changes to the Employee Plans Determination Letter Program). Specifically, the determination letter program is modified to:
  • Eliminate elective demonstrations regarding coverage and nondiscrimination requirements.
  • Provide that only employers who have made limited changes to their pre-approved volume submitter plans may file Form 5307.
This revenue procedure is effective February 1, 2012 for plans under the five-year remedial amendment cycle (other than terminating plans). For terminating plans and those under the six-year amendment cycle, this revenue procedure is effective May 1, 2012.
The IRS also issued Revenue Procedure 2012-8 which makes companion changes to the IRS user fee program.