IRS 2012 Cumulative List
- Pension Plan Limitations for 2014
- Final Regulations on Suspension or Reduction of Safe Harbor Contributions under Cash or Deferred Arrangements
When Is It Too Late? The Supreme Court Will Hear Case on Statute of Limitations Contained in Employee Benefit Plan
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- IRS 2011 Cumulative List
- Finally, a Final Regulation on Providing Investment Advice
- Pension Plan Limitations for 2012
- "For The World is Hollow and I Have Touched The Sky" — Brown v. Continental Airlines, Inc.: Have We Reached the Boundary of Fiduciary Responsibility?
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- IRS Revenue Ruling 2011-7 Provides Guidance Regarding 403(b) Plan Terminations
- Financial Crimes Enforcement Network Issues Final Regulations on Foreign Financial Reporting
- IRS Issues 2010 Cumulative List
- Cash Balance and Other Hybrid DB Plans Are Here To Stay
- Pension Plan Limitations for 2011
- New Law Permits Conversion of Pre-Tax and Other Accounts to Designated Roth Account within 401(k), 403(b) and Governmental 457(b) Plans
- Funding Relief for Multi-Employer Pension Plans
- Funding Relief for Single Employer Pension Plans
- Proposed Regulations on Foreign Financial Reporting, and What They Mean for Employee Benefit Plans and Fiduciaries
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- IRS Issues 2009 Cumulative List
- Eighth Circuit Reinstates 401(k) Plan Fee Lawsuit Against Wal‑Mart
- Pension Plan Limitations for 2010
- IRS Issues Final Regulations under Code Section 436
- Recent IRS Guidance Addresses Contribution of Unused Paid Time Off, Automatic Enrollment and Tax Notices
- Supreme Court Holds that Pension Plan May Apply a Benefit Formula That Treats Pre-Pregnancy Disability Act Pregnancy Leave Less Favorably Than Other Medical Leave
- IRS Issues Guidance on Suspension of Safe Harbor Nonelective Contributions
- Treasury Department Issues Final Regulations on Automatic Enrollment Plans
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- Pension Plan Limitations for 2009
- Heroes Earning Assistance and Relief Tax Act Adds Benefits for Those in Military Service
- Benefits Quiz
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- IRS Issues Guidance for New Distribution Requirements that Become Effective in 2008
- New Multiemployer Plan Disclosure Requirements — ERISA Section 101(k)
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- IRS Issues 2007 Cumulative List
- Pension Plan Limitations for 2008
- Final Section 403(b) Regulations: What Plan Sponsors Need to Know
- IRS Issues Final Regulations Affecting Section 403(b) Plans Covering Employees of Tax-Exempt Organizations, Public Schools and Churches
- Treasury Department Issues Final Regulations under Code Section 415
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- Pension Plan Limitations for 2007
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Regulations: Heinz and Utilization Test Included
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- Pension Plan Limitations for 2006
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- Treasury Department Issues Proposed Section 415 Regulations
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- Revenue Procedure 2005–23 — Internal Revenue Service Guidance for Implementing Heinz Decision
- Use of an Administrative Committee to Address Fiduciary Obligations of a Retirement Plan Sponsor
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- Proposed and Temporary Section 403(b) Regulations of Interest to Tax-Exempt Employers
- Missing Participants
- The American Jobs Creation Act of 2004: Employee Benefits Related Issues
- Pension Plan Limitations for 2005
- The Automatic Rollover of Mandatory Cash-Outs: The Department of Labor's Safe Harbor Final Regulations
- IRS Issues Final 401(a)(9) Minimum Distribution Regulations
- Unanimous Supreme Court Decision Determines That Post-Retirement Plan Amendment Violates ERISA's Anti-Cutback Rule
- PBGC Announces New Participant Notice Voluntary Correction Program
- DOL Addresses Modifications Made to Pre-Existing QDROs
- Revenue Procedure 200425 Extends Remedial Amendment Period Only for Certain Specified Disqualifying Provisions
- New Requirement for Automatic Rollovers of Small Cash-Outs from Qualified Plans: The Proposed Regulations
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- IRS Issues Guidance Clarifying Allocation of Plan Expenses to Inactive Participants
- New Legislation Clarifies Rule on Plan Loans to Servicemembers
- Proposed 401(k) Regulations Include Interesting ESOP Change
- Pension Plan Limitations for 2004
- Recent Court Cases on Cash Balance Plans
- Internal Revenue Service Simplifies and Streamlines the Employee Plans Compliance Resolution System
The Internal Revenue Service (the "Service") recently released Notice 2012–76, which contains the 2012 Cumulative List of Changes in Plan Qualification Requirements (the "2012 Cumulative List") described in Section 4 of Revenue Procedure 2007–44. The 2012 Cumulative List is to be used by plan sponsors and practitioners submitting determination letter applications for plans during the period beginning February 1, 2013 and ending January 31, 2014.
The 2012 Cumulative List applies primarily to the plan sponsors of individually–designed defined contribution plans (including ESOPs) and single employer individually–designed defined benefit plans that are in Cycle C, as well as governmental plans (including governmental multiemployer or multiple employer plans) that choose to file during Cycle C. Generally, an individually–designed plan is in Cycle C if the last digit of the plan sponsorís employer identification number ("EIN") ends in either 3 or 8.
The 2012 Cumulative List also applies to sponsors of defined benefit pre–approved plans (i.e., master and prototype ("M&P") or volume submitter ("VS") plans) for the second submission under the remedial amendment cycle set forth in Revenue Procedure 2007–44.
The 2012 Cumulative List informs plan sponsors of areas the Service has specifically identified for review in determining whether a plan filing in Cycle C has been properly updated. The 2012 Cumulative List specifically addresses law changes under the Pension Protection Act of 2006 ("PPA ’06"); the U.S. Troop Readiness, Veteranís Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007; the Heroes Earnings Assistance and Relief Tax Act of 2008 ("HEART Act"); the Worker, Retiree, and Employer Recovery Act of 2008 ("WRERA"); the Small Business Jobs Act of 2010 ("SBJA"); the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 ("PRA 2010"); and the Moving Ahead for Progress in the 21st Century Act ("MAP-21").
In this review cycle, the Service said that it will not consider any of the following:
Terminating plans must include all law changes in effect at the time of termination.
The 2012 Cumulative List includes those plan qualification requirements included in the 2008, 2009, 2010 and 2011 Cumulative Lists, as well as additional 2012 plan qualification requirements. It also includes those plan qualification requirements listed in the 2007 Cumulative List that are applicable to defined benefit pre–approved plans. The cumulative lists in effect prior to these dates (i.e., 2004 through 2006 and 2007 (with respect to defined contribution plans)) have been deleted. The utility of the cumulative list was enhanced by removing items that would have been previously reviewed in the case of a plan that was submitted during the initial Cycle C submission period (February 1, 2008 – January 31, 2009). In the case of a plan that has not been previously reviewed for items on earlier cumulative lists, the items from the earlier cumulative lists must be taken into account (such as in the case of a new plan that was established after the Cycle C submission period).
The 2012 Cumulative List includes the following "new" plan qualification requirements listed by section of the Code. All references are to the Code and Treasury Regulations unless otherwise specified.
401(a) 411(a) 411(a)(13) 411(b)(5) 411(d)(6) 415 417 420 436 If you have any questions regarding these provisions or your need to update your plan(s), please contact the Trucker Huss attorney with whom you regularly work.
Copyright © Trucker Huss. All rights reserved. This article is published as an information source for our clients and colleagues. The article is current as of the date shown above, is general in nature and is not the substitute for legal advice or opinion in a particular case. In response to new IRS rules of practice, we inform you that any federal tax information contained in this writing cannot be used for the purpose of avoiding tax–related penalties or promoting, marketing or recommending to another party any tax–related matters in this writing.
411(a) 411(a)(13) 411(b)(5) 411(d)(6) 415 417 420 436 If you have any questions regarding these provisions or your need to update your plan(s), please contact the Trucker Huss attorney with whom you regularly work.
411(a)(13) 411(b)(5) 411(d)(6) 415 417 420 436 If you have any questions regarding these provisions or your need to update your plan(s), please contact the Trucker Huss attorney with whom you regularly work.