Plan Amendment Deadlines Extended by IRS

The deadline for the RMD relief Section 2203 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act has been extended.

At the middle of last week, on August 3, the IRS announced this deadline extension in Notice 2022-33 for amending a retirement plan to reflect the provisions of the RMD relief waiver aspect of Section 2203.

  • For (A) a qualified plan or 403(b) plan that is not a governmental plan, or (B) and IRA, the extended amendment deadline is now 12/31/2025
  • For governmental retirement plans, including governmental 457(b) plans, later deadlines apply

Key Notice 2020-68 Modifications:

The extension of the deadlines for amending a retirement plan or IRA, via Notice 2022-33, to reflect certain provisions of the SECURE Act and the Bipartisan American Miners Act of 2019, is done so by modifying Notice 2020-68, 2020-38 IRB 567, as well as Notice 2020-86, 2020-53 IRB 1786.

An overview of the modifications are as follows:

  • The first paragraph under Q&A G-1(a) of Notice 2020-68
  • The first paragraph under Q&A G-1(b) of Notice 2020-68
  • Q&A G-1(c)
  • The first paragraph under Q&A G-1(d)

For detailed information regarding the specifics of the modifications for each, you can access the full article from the National Tax-Deferred Savings Association (NTSA) here: NTSA Article.

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