Posts Categorized: Retirement Plans

End of an Era – Determination Letter Program to Terminate

in Retirement Plans

On July 21, 2015 the IRS issued Announcement 2015-19, ending the regular determination letter program because of limited resources, and providing a transition period for certain plans. Effective Jan. 1, 2017, the IRS will no longer accept determination letter applications based on the staggered five-year determination letter remedial amendment cycles for individually designed plans. The last on-cycle determination letter filings will be Cycle A.  Sponsors of Cycle A plans will we allowed to submit determination letter applications during the period beginning February 1, 2016 and ending January 31, 2017. The determination letter program for individually designed plans will remain in place… Continue Reading

IRS Puts a Halt to Lump Sum Windows for In-Pay Retirees

in Retirement Plans

On July 9, 2015, the IRS announced its intention to propose rules prohibiting defined benefit pension plans from offering temporary lump sum windows to retirees receiving annuities.  Although the proposed rules have not yet been issued, the IRS has announced the prohibition will be effective retroactive to July 9, 2015, with certain grandfathered exceptions noted below.  As a result, plan sponsors will not have the opportunity to offer lump sum windows before the effective date unless planning for the lump sum windows was well underway.   (See “Grandfathered Windows” below.) Background.  Lump sum windows have been a key pension de-risking strategy… Continue Reading

Affect of Obergefell on Benefit Plans

in Court Cases, Health Benefits, Retirement Plans, Tax Issues, Welfare Benefits

For the second time in exactly two years, the United States Supreme Court has issued a landmark decision relating to same-sex marriages. Two years ago, in United States v. Windsor, the Court recognized same-sex marriages for federal law purposes. However, states were not required to recognize same-sex marriages entered into under the laws of another state. On June 26, 2015, in Obergefell v. Hodges, the Court went further, holding that all states must recognize a marriage as valid if it was valid in the jurisdiction in which it was performed, and also required that all states license same-sex marriages. State… Continue Reading