Under Revenue Procedure 2019-20, sponsors of individually designed statutory hybrid plans, including cash balance plans, have a short window of opportunity to file determination letter applications with the IRS by August 31, 2020. In addition, sponsors of merged plans have an ongoing opportunity to file determination letter applications within certain periods of time after the … Continue Reading
On September 3, 2019, the IRS issued Revenue Ruling 2019-19, which discusses participants’ and beneficiaries’ inclusion of income and qualified retirement plans’ withholding and reporting obligations for uncashed distribution checks. Although the Revenue Ruling describes only a qualified retirement plan under Code section 401(a), the same reasoning would most likely also apply to a Code … Continue Reading
The most recent decision in the ongoing Sun Capital saga provides no relief from pension withdrawal liability for private equity funds. The federal district court for the District of Massachusetts recently reaffirmed its 2016 ruling that two private equity funds were responsible for the unfunded pension liabilities of a bankrupt portfolio company. Consequently, private equity … Continue Reading
On October 29, 2018, the Departments of the Treasury, Health and Human Services, and Labor jointly issued proposed regulations providing employer plan sponsors greater flexibility in integrating health reimbursement accounts (HRAs) with other health insurance coverage. The proposed regulations would take effect for plan years beginning on or after January 1, 2020, and would make … Continue Reading
