IRS Revenue Procedure 2016-37: Changes to the Determination Letter Program, Ongoing Plan Compliance and Best Practices for Plan Sponsors

Lori Shannon and Monica Novak from Drinker Biddle and Chris Shankle, a member of the Advisory Committee on Tax Exempt and Government Entities, discussed the revised determination letter program under IRS Revenue Procedure 2016-37 and considerations for sponsors of individually designed qualified plans.

Key topics included:

• When determination letter applications will be accepted by the IRS.
• Changes to the remedial amendment period and plan amendment deadlines.
• IRS new annual Required Amendments List and Operational Compliance List.
• Converting to a pre-approved plan format.
• Action steps for sponsors of individually designed qualified plans.