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Compliance December 17, 2012
IRS Issues 2012 Cumulative List
The
Internal Revenue Service (IRS) has issued the 2012 Cumulative List of Changes
in Plan Qualification Requirements.
Reported by Rebecca Moore
Plans using this Cumulative List will primarily be single employer individually designed defined contribution (DC) plans and single employer individually designed defined benefit (DB) plans that are in Cycle C, and § 414(d) governmental plans (including governmental multiemployer or governmental multiple employer plans) that choose to file during Cycle C.
The IRS said it will not consider in its review of any determination letter application for the submission period that begins February 1, 2013, any guidance issued after October 1, 2012; statutes enacted after October 1, 2012; qualification requirements first effective in 2014 or later; or statutory provisions that are first effective in 2013, for which there is no guidance identified in the notice.
However, the agency noted, in order to be qualified, a plan must comply with all relevant qualification requirements, not just those on the 2012 Cumulative List.
Notice 2012-76 is at http://www.irs.gov/pub/irs-drop/n-12-76.pdf.