Tag Archives: IRS

2019 key administrative dates and deadlines for calendar-year defined contribution retirement plans

Milliman’s 2019 defined contribution retirement plan calendar with key administrative dates and deadlines is now available. The calendar lists relevant 2019 administrative dates encountered by most defined contribution retirement plans, including deadlines for government filings and participant disclosures. The calendar also provides short descriptions of the actions required to meet each deadline.

To download the calendar, click here.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

IRS updates revenue procedures for 2019
The Internal Revenue Service (IRS) published Internal Revenue Bulletin 2019-1, which includes the various revenue procedures, revised for 2019, for issuing letters, rulings, determination letters, and technical advice on specific issues related to employee benefits.

• Rev. Proc. 2019-1: Letter rulings, information letters, and determination letters—the schedule of user fees for letter rulings is included in Appendix A and reveals certain requests for letter rulings.
• Rev. Proc. 2019-2: Explains when and how technical advice is furnished by the various associate chief counsels and the division counsel/associate chief counsel to a director or an area director, and also appeals.
• Rev. Proc. 2019-3: Provides a revised list of tax code provisions under the jurisdiction of the various associate chief counsels and the division counsel/associate chief counsel on which the IRS will not issue rulings or determination letters.
• Rev. Proc. 2019-4: Provides procedures for furnishing ruling letters, information letters, etc. on matters related to tax code sections currently under the jurisdiction of the Commissioner of the Tax Exempt and Government Entities (TE and GE) Division.

For an electronic version of Internal Revenue Bulletin 2019-1 that contains these revenue procedures and user fee schedules, click here.

PBGC annual report of the participant and plan sponsor advocate
The Pension Benefit Guaranty Corporation (PBGC) released the 2018 Annual Report of the Participant and Plan Sponsor Advocate. This statutorily required report discusses the activities of the Office of the PBGC Participant and Plan Sponsor Advocate.

Notably, the report provides the second part of its study on single employer pension plan de-risking. Unlike the quantitative approach of the first part of the de-risking study, Part II took a qualitative approach, which consisted of a focus group from a small but diverse group of plan sponsors on varying paths toward de-risking. The small group format allowed for a deeper probe into the reasoning behind de-risking decisions, which can be helpful to inform and shape retirement policy for all Americans. The report also offers numerous recommendations for multiemployer plans.

To download the entire report, click here.

GASB implementation guide exposure draft on fiduciary activities
The Governmental Accounting Standards Board (GASB) has issued a proposed Implementation Guide that contains question and answers about the GASB’s new standards on accounting and financial reporting for fiduciary activities. The exposure draft proposes answers to dozens of questions about GASB Statement No. 84, Fiduciary Activities.

For more information, click here.

Notice providing interim guidance on excess remuneration and parachute payments
The IRS released Notice 2019-09, which provides interim guidance on the provisions of the new § 4960 added by the Tax Cuts and Jobs Act, and announces the intent of Treasury and the IRS to issue proposed regulations. Section 4960 provides that excess remuneration and excess parachute payments paid by an applicable tax-exempt organization to a covered employee are subject to an excise tax (currently 21%). This notice provides interim guidance defining (1) “applicable tax-exempt organization,” (2) “excess remuneration,” (3) “covered employee,” and (4) “excess parachute payment.” In addition, the notice instructs taxpayers on how to report and pay the excise tax.

For more information, click here.

2019 key administrative dates and deadlines for calendar-year multiemployer defined benefit plans

Milliman’s 2019 multiemployer defined benefit calendar with key administrative dates and deadlines is now available. The calendar lists relevant 2019 administrative dates encountered by most multiemployer defined benefit plans, including deadlines for governmental filings and participant disclosures. The calendar also provides short descriptions of the actions required to meet each deadline.

To download the calendar, click here.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

IRS releases specifications for electronic filing of Form 8955-SSA
The Internal Revenue Service (IRS) released Publication 4810, “Specifications for Electronic Filing of Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits.” The purpose of this publication is to provide the specifications for electronically filing Form 8955-SSA with the IRS. The publication must be used to prepare current and prior year Form 8955-SSAs.

To download the publication, click here.

403(b) preapproved plan program FAQs posted
The IRS has posted FAQs related to 403(b) preapproved plan programs on eligible adopting employers and reliance on letters. Questions include:

• Who can adopt a 403(b) prototype or volume submitter specimen plan?
• What is an IRS opinion or advisory letter for a 403(b) preapproved plan?
• To what extent can an adopting employer rely on a 403(b) prototype plan’s opinion letter?
• To what extent can an adopting employer rely on a 403(b) volume submitter plan’s advisory letter?

To access the FAQ, click here.

Two summary reports by Employee Plans Compliance Unit posted
The IRS posted two new reports from the Employee Plans Compliance Unit (EPCU): “Updating Frozen Defined Benefit Plans for Current Law and Other Compliance Issues” and “Nonqualified 401(k) Plans.”

During the Frozen Plan Amendments project, the EPCU looked at whether sponsors of frozen defined benefit plans had amended their plans for the Economic Growth and Tax Relief Reconciliation Act of 2001.

The EPCU Nonqualified 401(k) Plans project began in February 2013. The unit sent contact letters to a sample of plan sponsors that showed their 401(k) plans were nonqualified. The unit wanted to learn whether they made a mistake when selecting pension feature codes 2J and 3C on their Form 5500 series returns to describe their plan’s characteristics. Responses showed that 87% of plan sponsors in the sample made filing errors showing that their plans were not qualified 401(k) plans. A 401(k) plan must be a qualified plan.

IRS releases notice delaying the overhaul of the Form W-4 until 2020
The IRS published Notice 2018-92. This notice provides interim guidance for the 2019 calendar year on income tax withholding from wages and from retirement and annuity distributions. This notice provides that certain withholding rules in Notice 2018-14, 2018-7 I.R.B. 353, that applied for 2018 will remain in effect for the 2019 calendar year or, in the case of one such rule, until April 30, 2019. Also, the IRS and the Department of the Treasury intend to develop regulations under sections 3401 and 3402 of the Internal Revenue Code, as amended by section 11041 of the Tax Cuts and Jobs Act.

To read the entire notice, click here.

2019 key administrative dates and deadlines for calendar-year single-employer defined benefit retirement plans

Milliman’s 2019 key administrative dates and deadlines for calendar-year single-employer defined benefit retirement plans is now available. The calendar lists relevant 2019 administrative dates encountered by most single-employer defined benefit plans, including deadlines for quarterly contributions, determination letter applications, and funding notices. The calendar also provides a short description of the actions required to meet each deadline.

To download the calendar, click here.

Regulatory roundup

More retirement-related regulatory news for plan sponsors, including links to detailed information.

FAQs for participants and beneficiaries following California wildfires issued
The Employee Benefits Security Administration of the U.S. Department of Labor (DOL) released guidance for employee benefit plan participants and beneficiaries in the wake of the 2018 California wildfires.

To download the guidance, click here.

Postponement of deadlines for taxpayers affected by a federally declared disaster issued
The Internal Revenue Service (IRS) published Revenue Procedure 2018-58, which provides an updated list of time-sensitive acts, the performance of which may be postponed under sections 7508 and 7508A of the Internal Revenue Code (Code). Section 7508 postpones specified acts for individuals serving in the armed forces of the United States or serving in support of such armed forces in a combat zone or serving with respect to a contingency operation as defined in 10 U.S.C. § 101(a)(13).

To learn more, click here.