What is the deadline for amending a plan to comply with the final regulations under §415?
The final regulations under §415 that were published in the Federal Register on April 5, 2007 are generally effective for limitation years beginning on or after July 1, 2007. As provided in Rev. Proc. 2007-44, an interim plan amendment to comply with the final regulations must generally be adopted by the later of the last day of the plan year that includes the effective date of the regulations and the due date (including extensions) of the employer’s income tax return for the tax year that includes the effective date of the regulations. The following three examples illustrate this requirement. Example 1. Plan A’s plan year and limitation year are the calendar year. The tax year of Employer M, Plan A’s sponsor, is also the calendar year. The first limitation year of Plan A beginning on or after July 1, 2007 is the limitation year that begins January 1, 2008. Thus, for Plan A, the regulations are effective on January 1, 2008. The last day of Plan A’s plan year that includes January 1, 20