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New deadline for pre-approved defined contribution plans, opinion letter applications

Deadline for pre-approved defined contribution plans

The IRS today released an advance version of Rev. Proc. 2018-42 that extends the deadline for submitting on-cycle applications for opinion letters for pre-approved defined contribution plans for the third six-year remedial amendment cycle to December 31, 2018. Under Rev. Proc. 2017-41, this submission period was originally scheduled to expire on October 1, 2018.


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Rev. Proc. 2018-42 [PDF 32 KB] thus modifies Rev. Proc. 2017-41 by extending the deadline from October 1, 2018, to December 31, 2018.

The IRS in July 2017 issued Rev. Proc. 2017-41 [PDF 190 KB] modifying the procedures for issuing opinion and advisory letters on the form of qualified retirement plans submitted under the pre-approved plan program. The IRS intended for Rev. Proc. 2017-41 to simplify the program by restructuring the current master and prototype and volume submitter pre-approved programs into a single program that in turn increased the types of eligible plans and permitted greater flexibility in plan design options.   

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