News & Analysis as of

Retirement Plan Internal Revenue Service Lump Sum Payments

Morgan Lewis - ML Benefits

PBGC Modernizes De Minimis Distribution Rates

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

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

King & Spalding

Compensation and Benefits Insights - April 2019

King & Spalding on

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

Jackson Walker

ERISA Alert: An Update on Health and Welfare and Retirement Plans

Jackson Walker on

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

Snell & Wilmer

IRS Changes Course on Lump Sums to Retirees

Snell & Wilmer on

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

Dickinson Wright

The IRS Backtracks on Retiree Lump Sum Window Prohibition; Some Concerns Remain

Dickinson Wright on

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

Nelson Mullins Riley & Scarborough LLP

Retiree Lump-Sum Windows- IRS Changes Position

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

Kilpatrick

IRS Reopens Retiree Lump Sum Windows

Kilpatrick on

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

Winstead PC

Life with Conflict of Interest Starting to be Implemented and Retirement Plan Update

Winstead PC on

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

McDermott Will & Emery

Final IRS Regulations Simplify Pension Plan Requirements for Partial Annuity Distributions

McDermott Will & Emery on

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

Franczek P.C.

IRS to Prohibit Lump-Sum Cashout Windows for Pension Plan Retirees

Franczek P.C. on

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

Franczek P.C.

Employee Benefits Alert - July 2015

Franczek P.C. on

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

Morgan Lewis

New IRS Guidance on Lump-Sum Windows

Morgan Lewis on

The IRS has changed its position on lump-sum windows for retirees in pay status. On July 9, the Internal Revenue Service (IRS) issued Notice 2015-49, which prohibits sponsors of qualified defined benefit plans from...more

Littler

IRS Moves to Prohibit Lump Sum Windows for Retirees

Littler on

The IRS issued Notice 2015-49 (the "Notice") on July 9, 2015, effectively ending the ability of sponsors of qualified defined benefit pension plans ("DB Plan") to "de-risk" their plans by offering participants in pay status...more

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