IRS Memorandum On Applying 415(c) to DROPs

The IRS has an internal administrative memorandum advising agents how the Section 415(c) limits should be applied to DROPs in governmental plans. Document Excerpt  This memorandum provides direction to Employee Plans (EP) employees reviewing governmental defined benefit (DB) plans with deferred retirement option plan (DROP) features, setting forth administrative guidelines for applying the benefit and […]

No Presumption of Vesting in Retiree Health Benefits

The Supreme Court held that ordinary contract principles apply in determining whether retiree health benefits are vested. Document Excerpt’ In this case, the Court of Appeals applied the Yard-Man inferences to conclude that, in the absence of extrinsic evidence to the contrary, the provisions of the contractindicated an intent to vest retirees with lifetime benefits. […]

Guidance allowing extension of Governmental Plans to Charter School Employees

Notice 2015-7 provides guidance allowing governmental plans to cover charter school employees provided certain requirements are met. Document Excerpt The IRS and the Treasury Department anticipate issuing proposed regulations under § 414(d) of the Internal Revenue Code (Code) to define the term “governmental plan.” This document describes specific rules that the IRS and Treasury Department […]

Guidance for Certain Small Employers Unable to Access SHOP

Notice 2015-08 provides guidance on Section 45R for certain small employers unable to purchase health coverage through SHOP because the employer’s principal business address is in a county for which SHOP is currently not available. Document Excerpt  This notice provides guidance on section 45R of the Internal Revenue Code (Code) for certain small employers that […]

2015 Monthly National Average Bronze Level Premium

Revenue Procedure 2015-15 provides the average national monthly premium for bronze level plans under the Affordable Care Act to be used for purposes of the individual shared responsibility payment. Document Excerpt  This revenue procedure provides the 2015 monthly national average premium for qualified health plans that have a bronze level of coverage for taxpayers to […]

PBGC Website Updated To Reflect Increased Premiums

The increased premiums reflect changes made by the Multiemployer Pension Reform Act of 2014. Document Excerpt The per-participant flat premium rate for plan years beginning in 2015 is $57 for single-employer plans (up from a 2014 rate of $49) and $26 for multiemployer plans (up from a 2014 rate of $12). For information about future […]

Guidance on Funding Notice post HATFA

Field Assistance Bulletin 2015-01 provides guidance on the funding notice requirement of ERISA Section 101(f) after the enactment of HATFA. Document Excerpt This memorandum provides guidance to the Employee Benefits Security Administration’s national and regional offices on compliance by plan administrators of single-employer defined benefit plans with the annual funding notice requirements of section 101(f) […]

Guidance On Obtaining Determination Letters

As is customary, the IRS has released the -6 revenue procedure, i.e., Revenue Procedure 2015-6 which provides guidance on obtaining a determination letter from the IRS. Document Excerpt This revenue procedure sets forth the procedures of the Internal Revenue Service for issuing determination letters on the qualified status of pension, profit-sharing, stock bonus, annuity, and […]

Automatic Approval For Change in Funding Method

Announcement 2015-03 provides automatic approval for a change in funding method of a single employer defined benefit plan in the case of a takeover of the plan by a new service provider. Document Excerpt  This announcement provides automatic approval of a change in funding method with respect to a single-employer defined benefit plan under certain […]

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