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IRS Issues Final and Proposed Regulations on Hybrid Pension Plans

The IRS recently issued long-awaited final regulations on hybrid pension plans, along with proposed transitional relief for hybrid pension plans that are not in compliance with the final rules.  The newly issued final rules provide guidance on issues not covered in the final hybrid plan regulations that were issued in 2010, and clarify certain issues in the 2010 final regulations.  The final rules are generally effective for plan years beginning on or after January 1, 2016, except that provisions in the final rules clarifying provisions in the 2010 final rules are effective for plan...

Federal District Court Holds That Plan's One-Year Limitations Period Is Unenforceable Under State Law

On the heels of the Supreme Court’s decision in Heimeshoff v. Hartford Life & Acc. Ins. Co, a federal district court in New York has held in Halpern v. Blue Cross/Blue Shield of Western New York, 12-CV-407S (W.D.N.Y., Sept. 4, 2014) that a group health benefit plan’s shorter one-year limitations period is unenforceable because section 3221(a) of New York Insurance Law allowed for a two-year limitations period.  Despite the fact that the New York’s Superintendent of Insurance approved the plan and had discretion to approve policies with provisions deviating from...

Puerto Rico Treasury Issues Further Guidance Clarifying the Prepayment Window Rules

On September 29, 2014, the Puerto Rico Treasury issued Tax Policy Circular Letter No. 14-02 (“CL 14-02”) to provide answers to the most frequent questions made by plan sponsors and plan administrators of retirement plans in connection with the pre-payment rules and procedures originally established through Administrative Determination No. 14-16 of August 6, 2014 (“AD 14-16”).  This new guidance overrides and clarifies prior understandings under AD 14-16 with respect to the discretion of the plan administrator or sponsor to recognize pre-payments under...

HATFA Extends MAP-21 Pension Funding Stabilization

President Obama recently signed into law the Highway and Transportation Funding Act of 2014 (“HATFA”), which extends the pension smoothing provisions included in the 2012 Moving Ahead for Progress Act for the 21st Century (“MAP-21”).  MAP-21 amended Section 430 of the Internal Revenue Code (the “Code”) to set interest rates for pension plan funding valuations at a range around the 25-year average of historical interest rates.  Under MAP-21, the range was between 90% and 110% of the 25-year average for 2012, and would gradually expand to be between...

IRS Releases Draft ACA Reporting Form Instructions

On August 28, the Internal Revenue Service (IRS) released draft instructions for completing health insurance reporting forms required under the Affordable Care Act (ACA). The release of the instructions comes a month after the IRS released the draft forms employers and insurers must use to report information regarding health care coverage. Section 6056 of the Internal Revenue Code, as added by the ACA, requires “applicable large employers” to provide information to the IRS about the type of health coverage offered to their full-time employees for purposes of the large...


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Format: 2014-10-26
Format: 2014-10-26