Sponsors of Puerto Rico Qualified Plans May Need to File by April 15, 2015 to Secure Tax Qualified Status

Under Puerto Rico Internal Revenue Circular Letter 11-10, any restatement of a Puerto Rico qualified Plan or certain ?Ç£qualification amendments?Ç¥ must be filed with the Puerto Rico Treasury Department on or before the due date of the employer?ÇÖs income tax return for the taxable year during which the restatement or qualification amendment became effective. Thus, for a calendar year plan sponsor that restated a Puerto Rico qualified plan or made any qualification amendment effective in 2014 (including amendments required by the U.S. Supreme Court?ÇÖs decision in U.S. v. Windsor regarding same-sex spouses), such restatement or amendment must be filed with the Puerto Rico Treasury Department on or before April 15, 2015 (or any extended due date to file the employer?ÇÖs income tax return for 2014).