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Final IRS Regulations Update Present Value Calculations for Defined Benefit Plans and Expand Anti-Cutback Relief

Generally, a defined benefit plan provides an accrued benefit commencing at a participant’s Normal Retirement Date that pays a flat benefit over the lifetime of the participant. If a plan provides for a distribution as a...more

Treasury Issues Final Regulation on Constructing Yield Curve

The Treasury has published final regulations on the methodology for constructing the yield curve that underlies how present values are calculated for defined benefit plans. The final regulations are nearly identical to the...more

SECURE 2.0 Grab-Bag Brings Holiday Treats

This holiday week, the IRS issued its long-anticipated guidance on miscellaneous changes under SECURE 2.0 Act of 2022 (“SECURE 2.0”) that are effective now (or in short order). Specifically, Notice 2024-2 (“Notice”), covers,...more

Final Regulations Update Pension Plan Mortality Tables and Proposed Regulations Address COVID Impact on Substitute Tables

The IRS recently published final regulations regarding new mortality tables to be used for most qualified defined benefit plans. 88 Fed. Reg. 72,357 (Oct. 20, 2023). The new tables are effective for plan years starting in...more

Proposed Treasury Regulation on Constructing Yield Curve for Funding Purposes

On June 23, the Treasury published proposed regulations on the methodology for constructing the yield curve that underlies how present values are calculated for defined benefit plans (88 Fed Reg 41047).  The proposed...more

Upcoming Deadlines for Plan Sponsors – February 2022

Upcoming deadline alert! Plan sponsors should prepare for these upcoming February 2022 deadlines to ensure federal compliance and avoid penalties....more

Upcoming Deadlines for Plan Sponsors – January 2022

Upcoming deadline alert! Plan sponsors should prepare for these upcoming January 2022 deadlines to ensure federal compliance and avoid penalties....more

2021 Retirement Plan Year-End Amendments and Operational Compliance

As we approach the end of 2021, it’s again time for sponsors of 401(a) and 403(b) plans to review their plan documents and plan operations to ensure compliance with increasingly complex qualification requirements. While...more

IRS Guidance on Funding Relief and Elections Under the American Rescue Plan Act of 2021

On July 30, the Internal Revenue Service issued Notice 2021-48, providing guidance on how plans should implement the funding relief provisions contained in the American Rescue Plan Act of 2021 (“ARPA” or “Act”). Below we...more

IRS Clarifies Partial Plan Termination Relief Under 2020 Legislation

On April 27, the Internal Revenue Service (“IRS”) issued informal guidance on partial plan terminations as part of the COVID-related tax relief provided under The Taxpayer Certainty and Disaster Tax Relief Act of 2020 (the...more

A Review of the Single-Employer Funding Provisions Under the American Rescue Plan Act

On March 11, 2021, President Biden signed into law the American Rescue Plan Act (Pub. Law 117-2, the “Act” or “ARPA”). The Act, among other things, provides significant funding relief for single-employer defined benefit...more

IRS Issues Final Regulations Updating Minimum Required Distribution Rules

On November 5, 2020, the Internal Revenue Service (“IRS”) released final regulations under section 401(a)(9) of the Internal Revenue Code (“IRC”). 85 Fed. Reg. 72472 (Nov. 12, 2020). The final regulations, which closely...more

IRS and PBGC Give Sponsors Until January 4, 2021 to Make Contributions Under the CARES Act

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) passed earlier this year delayed the due date of quarterly and final contributions otherwise due in calendar year 2020 to January 1, 2021. But because...more

IRS and PBGC Guidance on Single-Employer Defined Benefit Funding Relief Under The CARES Act

On July 31, the IRS issued Notice 2020-61 (the “Notice”) to provide guidance related to the special funding rules applicable to single-employer defined benefit pension plans under the Coronavirus Aid, Relief, and Economic...more

SECURE Act Testing Relief for Closed/Frozen Defined Benefit Plans

In recent years, many defined benefit (“DB”) pension plan sponsors have taken action to limit ongoing coverage and benefit accruals of their DB plans.  Over time these plans may have difficulty continuing to satisfy the...more

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