IRS Issues 2005 List of Changes Used for Drafting Certain Plans

December 14, 2005 – The IRS has issued Notice 2005-101, 2005 Cumulative List of Required Changes in Plan Qualification Requirements. This list describes various statutory, regulatory and guidance changes that are to be considered when drafting individually designed plans that fall under “cycle A” of the IRS’s new staggered remedial amendment period (RAP) regimen. Cycle A includes those individually designed plans whose adopter’s employer identification number (EIN) ends in the numeral 1 or 6.

The cumulative list used by drafters of mass submitter documents, including master/prototype and volume submitter plans, is the 2004 cumulative list. This is the list that is being used in the drafting of BISYS mass submitter documents in the EGTRRA restatement process.

Notice 2005-101 may be found at http://www.irs.ustreas.gov/pub/irs-drop/n-05-101.pdf.