Inflation is at a 40-year high – reaching 8.6% in May, according to a Bureau of Labor Statistics (BLS) news release earlier this month. The rise of consumer product costs, including food and gasoline, have all contributed to...more
The Pension Benefit Guaranty Corporation (PBGC) published a final rule (Final Rule) on September 9 providing that effective January 1, 2021, it will use the interest and mortality assumptions under Internal Revenue Code...more
August 2019 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts AFRs - Important federal interest rates continued to drop for August 2019. The August...more
In IRS Notice 2019-18, the IRS announced that it no longer intends to issue regulations that prohibit pension plans from offering to retirees who have already begun annuity payments the choice to receive the value of the...more
Due to an Internal Revenue Service (IRS) change in course published in Notice 2019-18, plan sponsors may now offer retirees lump-sum windows as another pension “de-risking” option. Plan sponsors considering pension de-risking...more
IRS Re-Opens the Door to Retiree Lump Sum Windows - The IRS recently issued Notice 2019-18, reversing its prior position set forth in Notice 2015-49 that offering retirees in pay status the opportunity to elect a “cash...more
The IRS previously issued several Private Letter Rulings permitting defined benefit plans to offer lump sum windows during which retirees receiving annuity payments could elect to receive the actuarial equivalent of their...more
Health and Welfare Plan Update - It is 9:00 p.m., do you know where your health plan data is? As IT systems continue to expand, and data is accessed, moved and stored in many new and different ways, the Office for Civil...more
Over the past several years, sponsors of defined benefit pension plans have examined and implemented ways to reduce their pension liabilities. This is sometimes referred to as “de-risking.” One de-risking option is for a plan...more
Defined benefit pension plans can be troublesome for sponsoring employers to maintain. The long-term liability for funding pension benefits coupled with unpredictable investment returns creates volatility. Companies...more
On March 6, 2019, the IRS announced that it will not amend the minimum required distribution regulations under Code section 401(a)(9) to expressly prohibit lump-sum window elections for retirees who are already receiving...more
In Notice 2019-18, the Internal Revenue Service (the “IRS”) changed its position and now will permit employers to offer lump sum payments to retirees who are currently receiving annuity payments from a defined benefit plan....more
In an about-face from 2015 guidance, the IRS announced in Notice 2019-18 that no regulatory amendments are forthcoming to prohibit retiree lump sum windows for defined benefit pension plans. ...more
One de-risking tool for employers with defined benefit pension liabilities is to allow participants to receive lump-sum distributions. Although lump sums result in a short-term cash drain, they reduce the plan’s long-term...more
Pension plan sponsors have been looking for opportunities to manage their growing pension liabilities for many years now. In 2015, the Internal Revenue Service (IRS) closed the door on sponsors who were considering offering...more
The IRS and the Treasury Department released Notice 2019-18 on March 6, which serves as a retraction of prior administrative guidance under Notice 2015-49 and indicates that the IRS no longer intends to propose regulations...more
On March 6, 2019, the Internal Revenue Service (IRS) issued Notice 2019-18 (Notice), announcing that it is retracting its previous position that prohibited pension plan sponsors from offering lump-sum cashouts to retirees who...more
In 2015, the IRS limited the de-risking options available to defined benefit pension plans by effectively prohibiting lump sum windows to retirees who are currently receiving annuity payments (known as “retiree lump sum...more
Fee Changes and Disclosures Post Conflict of Interest Regulations Initial Partial Effective Date - The effects of the U.S. Department of Labor’s (“DoL”) conflict of interest or fiduciary regulation and related prohibited...more
Employer-sponsored retirement plans come in many varieties. For example, under 401(k) and other defined contribution plans, employees and, often, employers may make specific contributions to an employee’s plan account...more
The Department of Treasury and Internal Revenue Service issued final regulations addressing the minimum present value requirements for pension benefits payable partly as an annuity and partly in an accelerated form, usually a...more
As described in a prior alert, the IRS issued Notice 2015-49, which abruptly announces the IRS’s intention to prohibit lump-sum cashout windows for pension plan retirees already in pay status. The IRS intends to prohibit...more
The Internal Revenue Service (IRS) recently issued two significant notices for employers that sponsor defined benefit pension plans, particularly those considering lump-sum windows as a “de-risking” option for their plans....more
Many defined benefit plan sponsors are looking for ways to reduce the on-going liability and the volatility of the annually required contributions to their defined benefit plans, which is sometimes referred to as...more
Major Revisions to Qualified Plan Determination Letter Process Announced - Effective January 1, 2017, the staggered five-year determination letter remedial amendment cycles for individually designed plans will be...more