Health and Welfare Plan Compliance: Health Plan Identifier Deadline Approaching

As anticipated for the last several months, on July 21, 2015, the Internal Revenue Service (IRS) announced the upcoming end of the determination letter program for individually designed retirement plans. Announcement 2015-19 provides that effective January 1, 2017, determination letters for individually designed plans will be issued only for (a) initial qualification of new plans and (b) plan terminations. (A "new" plan is not defined in a meaningful way. For example it is not clear whether plans from mergers or spinoffs will be considered "new.")

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