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IRS Releases 2015 Pension Plan Limits

The Internal Revenue Service recently released a detailed list of pension plan and other retirement-related contribution and compensation limitations for tax year 2015 that were triggered by an increase in the cost-of-living index.  As stated in the release, “[m]any of the pension limitations will change because the increase in the cost-of-living index met the statutory thresholds that trigger their adjustment. However, other limitations will remain unchanged for 2015.”The following highlights a few key changes to the limits for retirement plans:Elective deferral...

CMS Clarifies Health Plan ID Requirement for Wrap Plans

The Centers for Medicare and Medicaid Services (CMS) has revised its Health Plan ID (HPID) FAQs to provide clearer guidance for employers who wrap multiple self-funded benefit programs into a single ERISA plan for purposes of the annual Form 5500 filing. In what was previously unclear, the updated guidance confirms that a  plan sponsor may obtain a single HPID for all self-funded “controlling health plans” (CHP) offered through a wrapped ERISA plan.  The FAQ provides the following example: For example, an employer that sponsors a single ERISA plan that includes...

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...


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Format: 2014-10-30
Format: 2014-10-30