Recent IRS Guidance Prohibits Lump-Sum Windows for Pension Retirees, Updates Pension Mortality Tables for 2016

By and on September 3, 2015

The Internal Revenue Service (IRS) recently issued two significant notices for employers that sponsor defined benefit pension plans, particularly those considering lump-sum windows as a “de-risking” option for their plans. In Notice 2015-49, the IRS notified plan sponsors that they are no longer permitted to offer retirees in pay status the option to take a lump-sum payment in lieu of ongoing annuity payments. Plan sponsors may, however, continue to offer a lump-sum payment option to deferred vested participants not in pay status. In Notice 2015-53, the IRS released updated mortality tables for 2016 and delayed the issuance of new regulations, which could incorporate new mortality assumptions recommended by the Society of Actuaries that many believe would increase pension funding liabilities and minimum lump-sum payments.

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Jeffrey Holdvogt
Jeffrey (Jeff) M. Holdvogt advises clients regarding a wide range of employee benefits matters. He focuses primarily on the design and administration of complex pension, defined contribution and executive deferred compensation arrangements. Jeff counsels privately and publicly held corporations on ongoing day-to-day retirement and executive compensation issues, as well as employee benefits design and transition matters arising from corporate mergers, acquisitions and divestitures. Read Jeff Holdvogt's full bio.


Maggie McTigue 
Maggie McTigue focuses her practice on employee benefits matters relating to pension and 401(k) plans, executive compensation, and health and welfare benefit plans. She regularly assists clients with employee benefit plan filings and notices required by the Department of Labor and the Internal Revenue Service. Maggie also has experience regarding plan investment issues under the Employee Retirement Income Security Act of 1974 (ERISA). Read Maggie McTigue's full bio.

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