I have a cash balance defined benefit plan which was adopted on Dec 1, 06. We bought the company (on Dec 1, 2008) that had created the plan and don't think a determination letter application was ever filed. We'll check with the IRS to be sure but wanted to know when do we file for the new plan. I realize a determination letter isn't required but assuming we want to file for one (that's another discussion) do we use the Cycle in which our EIN number fits (I assume that rather than the old company's EIN number). Is there some rule that we have until the end of the remedial amendment cycle in which the plan was adopted (I found various articles which seem to suggest that)? ANy ideas? Silly me I called the IRS - they'll get back to me in 15 days if at all.
Thanks