After the Internal Revenue Service (“IRS”) finalized significant changes on hardship distribution regulations in September, the deadline for adopting certain retirement plan amendments has been extended to December 31, 2021. Groom Principals Louis Mazawey and Elizabeth Dold discussed their thoughts on the extension in the Tax Notes article, “IRS Relieves Uncertainty About Timing of Plan Amendments.” In discussing the changes, Mazawey stated, “It says that certain amendments that are related to hardship changes, but more in the nature of discretionary changes, still get the extended deadline for required hardship plan amendments.” Dold remarked that “…practitioners were left with a lot of uncertainty regarding the timing of the interim amendments for hardships for pre-approved plans, with a particular concern for non-calendar year plans.”
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