In Announcement 2015-19, the IRS announced the elimination of the five year remedial amendment cycle for individually designed retirement plans effective as of January 1, 2017. This means that after January 1, 2017, individually designed retirement plans will no longer be eligible to receive favorable determination letters every five years. The Announcement leaves the current […]
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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 “de-risking.” One de-risking strategy involves offering lump-sum payouts to retirees in pay status as a replacement of their annuity payments. This strategy […]
KH
In 2013, the Supreme Court, in United States v. Windsor, struck down Section 3 of the Defense of Marriage Act (“DOMA”) which defined marriage, for Federal purposes, as between one man and one woman. The Windsor ruling resulted in numerous Federal benefits for same-sex couples who were legally married in a jurisdiction that performed same-sex […]
KH
In its April 1, 2015 Employee Plans News, the IRS stated that defined contribution plan sponsors must maintain hardship distribution records and that plan sponsors cannot rely on electronic participant self-certification for hardship distributions. The IRS indicated that plan sponsors should keep the following: Documentation of the hardship request, review and approval; Financial information that […]
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In Tibble v. Edison International, Justice Breyer held, for a unanimous Supreme Court, that “a fiduciary normally has a continuing duty of some kind to monitor investments and remove imprudent ones.” In so ruling, the Court reversed a decision from the Ninth Circuit, which held, in essence, that plan fiduciaries could not be held responsible […]
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The IRS recently announced changes that make it significantly easier to correct employee deferral mistakes (also known as elective deferrals) in qualified retirement plans. The changes make modifications to the IRS’ Employee Plans Compliance Resolution System (“EPCRS”), which is the IRS’ comprehensive correction program for qualified retirement plans. Automatic Enrollment Correction Relief If a qualified […]
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The Department of Labor recently issued final regulations implementing the annual funding notice that defined benefit plans are required to provide under Section 101(f) of ERISA. The final regulations are similar to the proposed regulations and the guidance issued in Field Assistance Bulletin 2009-01 and Field Assistance Bulletin 2013-01. Generally, administrators of defined benefit plans […]
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The IRS recently announced cost of living adjustments for 2015. The key dollar amounts for retirement plans (compared to the 2014 dollar limits) are noted below. Maximum Qualified Retirement Plan Dollar Limits 2015 2014 Limit on Section 401(k) deferrals (Section 402(g)) $18,000 $17,500 Dollar limitation for catch-up contributions (Section 414(v)(2)(B)(i)) $6,000 $5,500 […]
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The abrupt departure of Bill Gross from PIMCO leaves many investors pondering their next move. Should an investor stay the course and see how PIMCO’s new investment team performs? Should an investor leave and follow Mr. Gross to Janus Funds? Should an investor rush to find a new bond fund manager? These questions are particularly important […]
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The IRS recently issued guidance on the use of longevity annuities in defined contribution plans and IRAs. These longevity annuities are known as “qualified longevity annuity contracts” or “QLACs.” A QLAC is a deferred annuity that begins at a specified age, but not later than age 85. This type of annuity allows individuals to have […]
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