The IRS released Revenue Procedure 2019-20, which expands the determination letter program to include:
- Statutory hybrid plans – plan sponsors may submit determination letter applications for statutory hybrid plans from September 1, 2019, through August 31, 2020.
- Plan mergers – plan sponsors may submit determination letter applications for certain merged plans on a continuing basis.
- Remedial amendment period – a limited extension of the remedial amendment period and a special sanction structure.
Plan sponsors may continue to submit determination letter applications for initial plan qualification and for qualification upon plan termination, as provided in Rev. Proc. 2016-37.