IRS Expands Determination Letter Program for Mergers of Qualified Plans Following Corporate Transactions
May 8, 2019
Authored by: Adam Braun and Lisa Van Fleet
The IRS recently reversed course on the availability of the determination letter program for merged qualified retirement plans – thereby providing new alternatives for integrating qualified retirement plan benefits in the context of corporate transactions.
Merged Plan Relief: Rev. Proc. 2019-20, released on May 1, 2019, expands the IRS’ determination letter program for individually designed qualified retirement plans (e.g., defined benefit plans or defined contribution plans) that result from a merger of two or more qualified retirement plans following a corporate merger, acquisition or other similar business transaction (a “Merged Plan”). The newly expanded program will be available beginning September 1, 2019 and continuing on an ongoing basis.
Eligibility: To be eligible for the determination letter program:
- The Merged Plan must be a combination of two or more qualified retirement plans maintained by previously unrelated entities (i.e., entities that are not members of the same controlled