WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
As recently noted by the US Department of Labor (“DOL”), since the passage of the Employee Retirement Income Security Act of 1974 (“ERISA”), “the retirement plan landscape has changed significantly, with a shift from defined...more
The Internal Revenue Service (IRS) released proposed regulations amending Employment Tax Regulations (26 CFR Parts 31 and 35) under section 3405 of the Internal Revenue Code (IRC). The regulations propose new rules for...more
There are several tools that can be used to correct or fix governmental plan problems. First, some classification. Practically all the retirement plans we discuss are “tax-advantaged” in one form or another. However,...more
People complain a lot about life these days, but one fun fact is that people are living longer than they did just 20 years ago. Thankfully, the Internal revenue Service (IRS) noticed too....more
INTRODUCTION - Now that §401(k) plans have replaced traditional pension plans as the overwhelming type of employer-sponsored type of retirement plan, there is a growing concern that many employees are not equipped to make...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
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
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
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
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
Typically, when a participant receives annuity payments from a defined benefit pension plan where he or she has a basis in the benefit (what Code Section 72 calls an “investment in the contract”), a portion of the payment is...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
The PBGC has recently initiated efforts to enhance retirement security for Americans by promoting lifetime income options (i.e., annuitized benefits). As part of these efforts, as well as those of the IRS and U.S. Department...more
401(k) participants face the risk of outliving retirement assets. However, earlier this month, the Internal Revenue Service and the Treasury Department issued final regulations that make it easier for 401(k) plans, individual...more
On December 31, 2012 the Internal Revenue Service (IRS) released Revenue Procedure 2013-12 which replaces existing Revenue Procedure 2008-50, the procedure for voluntary correction of qualified retirement plan errors. The...more