The IRS has issued Notice 2018-91 containing the Required Amendments (RA) List for 2018 for individually designed retirement plans to maintain their qualified plan status.
When the agency ended its determination letter program effective January 1, 2017, it said it would publish an RA List after October 1 of each year. Individually designed plan sponsors must adopt any item placed on the list by the end of the second calendar year following the year the list is published.
There are no entries listing changes in qualification requirements on the 2018 RA List.
The IRS reminds plan sponsors that an RA List does not include guidance issued or legislation enacted after the list has been prepared and also does not include:
- Statutory changes in qualification requirements for which the Treasury Department and the IRS expect to issue guidance (which would be included on an RA List issued in a future year);
- Changes in qualification requirements that permit (but do not require) optional plan provisions (in contrast to changes in the qualification requirements that cause existing plan provisions, which may include optional plan provisions previously adopted, to become disqualifying provisions); or
- Changes in the tax laws affecting qualified plans that do not change the qualification requirements under Internal Revenue Code Section 401(a) (such as changes to the tax treatment of plan distributions, or changes to the funding requirements for qualified plans).
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