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Annual IRS Revenue Procedures Are Out

Each year, the IRS updates Revenue Procedures (Rev. Proc. 2026-1 through Rev. Proc. 2026-7) for policies and procedures applicable to different IRS divisions. Internal Revenue Bulletin: 2026-01 | Internal Revenue Service. The key Revenue Procedure for employee plans is Rev. Proc. 2026-4, which provides procedures for IRS determination letters for qualified plans, closing agreements, certain employee plan private letter rulings (PLRs), etc. It also provides the annual user fees for various IRS filings.

Also notable is Rev. Proc. 2026-1, which applies to most PLRs, and Rev. Proc. 2026-3, which lists issues that the IRS will not rule on.

Pricing for 2026:

  • Form 5300 (determination letter): $4,000 (up from $2,700)
  • Form 5307 (pre-approved determination letters): $2,000 (up from $1,200)
  • Form 5310 (final determination letter): $4,500 (up from $3,500)
  • PLRs: certain employee benefits matters — $18,500 (up from $12,500); others $43,700 (no change)
  • VCP filings: $2,000, $3,500, $4,000 (depending on plan size) (up from $1,500, $3,000, $3,500)
  • Group VCP filings: $13,500 for initial 20 plans, $250 for each additional, $50,000 cap (up from $10,000 initial filing)

And for those who will be submitting determination letters or private letter ruling applications in the coming year, Rev. Proc. 2026-4 makes clear that all determination letters must be filed electronically, and the user fees for determination letters and PLRs are not returned if there is an omission of a material fact.

“1) Regular submissions under VCP. (For a special rule relating to terminating Orphan Plans see section 4.08 of Rev. Proc. 2021-30): Plans with assets of — (a) $500,000 or less - $2,000 (b) Over $500,000 to $10,000,000 - $3,500 (c) Over $10,000,000 - $4,000”

Tags

retirement programs, plan services & providers, employers & sponsors, retirement services