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Upcoming Compliance-Related Deadlines: Be Aware

Practice Management
Summer is here, and part of the heat this year is compliance-related. Here are some deadlines to keep in mind:
 
July 15, 2020
 
Date by which, under Notice 2020-23 and 2020-32, certain actions that were due to be performed on or after March 30, 2020, and before July 15, 2020 can be performed.
  
  • Actions to correct employment tax reporting errors using the interest-free adjustment process under Code Sections 6205 and 6413.  
  • Applications for a funding waiver under Code Section 412(c) for a defined benefit plan that is not a multiemployer plan. 
  • Regarding a multiemployer defined benefit plan, actions due to be performed on or before the dates described in Code Sections 432(b)(3), 432(c)(1), 432(e)(1), 432(c)(6) and 432(e)(3).  
  • Regarding a CSEC plan, actions to be performed on or before the date described in Code Sections 433(c)(9) , 433(f)(3)(B), Section 433(j)(3) and Section 433(j)(4).
  • Filing Form 5330 and payment of the associated excise taxes. 
  • Regarding the IRS Employee Plans Compliance Resolution System (EPCRS) and a compliance statement issued under VCP, implementation of all corrective actions, including adoption of corrective amendments required by the compliance statement. 
  • Requests for approval of a substitute mortality table in accordance with Code Section 430(h)(3)(C).
Notice 2020-35, provides that these actions concern the following:
 
  • employment taxes;
  • exempt organizations; and
  • Forms 5498, 5498-SA or 5498-ESA.
July 31, 2020
 
Date by which calendar-year plans covered by ERISA are to file the Form 5500.
 
Date by which, under Notice 2020-23 and Notice 2020-32, pre-approved defined benefit plans are to perform the following actions:  
 
  • adoption of a pre-approved DB plan that was approved based on the 2012 Cumulative List;  
  • submission of a determination letter application under the second six-year remedial amendment cycle; and
  • actions that are otherwise required to be performed with respect to disqualifying provisions during the remedial amendment period that would otherwise end on April 30, 2020.
Aug. 1, 2020
 
Beginning of the period during which, under Announcement 2020-7, the IRS will accept from any employer eligible to submit a determination letter request an application for an individual determination letter under the third six-year remedial amendment cycle for pre-approved DC plans. The period ends on July 31, 2022.

Aug. 31, 2020
 
Due date by which, under Notice 2020-23 and Notice 2020-32, Forms 5498, 5498ESA and 5498-SA, are to be filed.
End of the 12-month period by which statutory hybrid plans may submit determination letter applications under Revenue Procedure 2019-20.

Sept. 1, 2020
 
Date on which penalties for a postponed filing of Forms 5498, 5498ESA and 5498-SA will begin to accrue.
All comments
Susan Ambler
3 years 9 months ago
Hi! Can you please check over the Notices again? Where, exactly, are you finding that the 403(b) Remedial Amendment Period date was moved from its already-extended end date of June 30 to July 15? Thanks!