Deadlines are a big a part of worker profit plan administration. The previous 12 – 18 months have contributed to potential confusion about commonplace deadlines and added new deadlines plan directors is not going to wish to overlook. Throughout this era, the IRS created a one-time window deadline, revealed extensions for some plans’ deadlines, and different deadlines weren’t prolonged however are quickly approaching. July and August 2020, convey probably the most speedy deadlines for plan directors.
In March, as a part of the COVID-19 reduction, the IRS prolonged the deadline for the tip of the second six-year remedial modification cycle for pre-approved (together with quantity submitter) outlined profit plans to July 31, 2020. The identical reduction postponed the start of the Cycle three remedial modification interval to August 1, 2020, however the finish date for Cycle three stays January 1, 2025. We initially mentioned this extension in a March 2020, weblog.
The IRS opened the dedication letter program by means of its Income Process 2019-20, revealed in Might of 2019. The income process completely opened the dedication letter program for Individually Designed Plans (IDP) that meet the necessities of a “merged plan” as outlined within the income process. The process additionally opened a restricted, 12-month window for statutory hybrid plans, e.g., money steadiness plans, to submit for a dedication letter. That 12-month window ends August 31, 2020. As we acknowledged in our Might 2019, weblog, plan sponsors and practitioners would welcome further, periodic alternatives to acquire dedication letters on different plans.
The IRS additionally issued COVID-19 reduction extending Type 5500 submitting deadlines for some plans primarily based on the plan year-end date. The reduction ended on July 15, 2020, and DID NOT prolong submitting deadlines for calendar yr plans. The Type 5500 or Type 5558 extension submitting deadline for a 2019 calendar yr plan stays July 31, 2020. All different submitting deadlines related to Type 5500 filings for plan years ending after December 31, 2019, will not be prolonged and needs to be filed well timed as in prior years in accordance with the plan year-end date.
The Backside Line:
Pre-approved outlined profit plans’ second six-year remedial modification interval ends July 31, 2020;
The dedication letter submission window for statutory hybrid plans, e.g., money steadiness plans, ends August 31, 2020; and
Calendar yr plans required to file Type 5500s should nonetheless file the Type 5500 or the Type 5558 extension by July 31, 2020.
Jackson Lewis P.C. © 2020Nationwide Legislation Overview, Quantity X, Quantity 206