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CCH® PENSION AND BENEFITS — 3/19/07

Staggered amendment cycles working well, IRS official states

The new process of working on determination applications based on remedial amendment cycles has already demonstrated its superiority over the previous determination letter program, according to IRS Employee Plans Director Joseph Grant, in remarks made at a recent benefits conference held in Los Angeles.

Under the new process, Grant stated, the time to process a determination letter has decreased from about 324 to 242 days. EP's goal, he said, is to decrease processing time for determination letters and voluntary compliance applications to 120 days. An additional benefit to the IRS of the new process is that, unlike in the past, EP agents have not had to have been pulled from their examination and enforcement work to handle a backlog of determination applications.

Cycle A applications below estimates

Grant expressed some surprise that, for Cycle A, the IRS had only received 1,100 applications as of mid-January 2007, instead of the 4,000 applications they expected. Conference attendees noted that many practitioners preferred to send applications on the last day of the cycle, just in case new law or regulatory changes were made. In response, Grant assured practitioners that new law or regulatory changes made subsequent to the issuance of the cumulative list for a cycle would not affect the issuance of determination letters for that cycle. Therefore, it was not advantageous to delay submission.

For more information on this and related topics, consult the CCH Pension Plan Guide.

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