News & Analysis as of

Benefit Plan Sponsors Private Letter Rulings

McDermott Will & Emery

How Pending Fishing Boat Cases at the Supreme Court Could Rock the Benefits Plan Boat

McDermott Will & Emery on

Thanks to two cases about federally mandated observers on fishing boats, judicial deference to agencies is likely to soon get weaker – and more unpredictable – with wide-ranging impacts for employee benefits. Less deference...more

Snell & Wilmer

Design Considerations for Medical Emergency Leave-Sharing Programs

Snell & Wilmer on

Employers often allow employees to donate leave to co-workers who are experiencing medical emergencies. If properly structured, these leave transfers can be excluded from the gross income of the donor employee and included in...more

McDermott Will & Emery

IRS Opens the Door to Lump Sum Payment Windows for Retirees in Pay Status

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

Laner Muchin, Ltd.

IRS No Longer Prohibits Lump Sum Payouts To Retirees In Pay Status

Laner Muchin, Ltd. on

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

BCLP

IRS Takes Step Towards De-Risking Retiree Lump Sum Windows

BCLP on

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

Proskauer - Employee Benefits & Executive...

IRS Reopens Opportunity to Cash Out Retirees in Pay Status—At Least For Now

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

Poyner Spruill LLP

IRS Announces Retiree Lump-Sum Windows Are Back On The Table

Poyner Spruill LLP on

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

Winstead PC

Another Lesson on Bullet Proofing Your Claims Process

Winstead PC on

On July 12, 2018, a previous alert entitled “Bullet Proofing Your Claims Process” discussed lessons learned from a recent 5th Circuit decision in White v. Life Insurance Company of North America, (5th Cir. June 13, 2018,...more

Bradley Arant Boult Cummings LLP

IRS Approves the Use of a 401(k) Plan to Help Tackle Student Loan Debt - Employee Benefits Alert

The Internal Revenue Service (IRS) has issued a private letter ruling approving of an employer’s program to provide employees a retirement plan contribution conditioned on student loan repayments. Specifically, the IRS found...more

McDermott Will & Emery

Recent IRS Guidance Prohibits Lump-Sum Windows for Pension Retirees, Updates Pension Mortality Tables for 2016

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

Snell & Wilmer

The IRS Takes Aim at De-Risking of Defined Benefit Plans

Snell & Wilmer on

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

Foley & Lardner LLP

The IRS Tosses Plan Sponsors a Curveball: New Guidance Throws Out One Method of Pension Plan De-Risking

Foley & Lardner LLP on

In recent guidance, the IRS surprised plan sponsors with its plan to prevent them from using one means of “de-risking” their defined benefit pension plans to reduce their pension plan liabilities. In Notice 2015-49, the IRS...more

King & Spalding

Five New IRS Private Letter Rulings Confirm IRS’s Position Allowing Retiree Cashouts

King & Spalding on

We reported in 2012 on two private letter rulings (“PLRs”) issued by the IRS (PLR 201228045 and PLR 201228051) blessing certain retiree cashout programs. A retiree cashout program is a de-risking strategy used by defined...more

Eversheds Sutherland (US) LLP

IRS Releases Additional Rulings on Lump-Sum Windows

The practice of offering lump-sum distributions has become increasingly popular among defined benefit plan sponsors looking to decrease volatility or other defined benefit plan risks. In some situations, plan sponsors offer...more

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