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ARTICLE · 15 OCTOBER 2014

IRS Issues Final And Proposed Hybrid Plan Regulations

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On September 19, 2014, the Internal Revenue Service released additional final regulations clarifying the rules regarding hybrid defined benefit pension plans.

United StatesEmployment and HR
Andrea Rattner
Andrea Rattner
Ira Bogner
Ira Bogner
Paul Hamburger
Paul Hamburger
Lisa Berkowitz Herrnson
Lisa Berkowitz Herrnson
Emily Erstling
Emily Erstling
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On September 19, 2014, the Internal Revenue Service ("IRS") released additional final regulations clarifying the rules regarding hybrid defined benefit pension plans. At the same time, the IRS also issued proposed regulations providing transition guidance for plan amendments to comply with the regulatory market rate of return requirements without violating the anti-cutback rules of Section 411(d)(6) of the Internal Revenue Code (the "Code"). Together, these regulations modify and supplement the 2010 IRS final and proposed regulations regarding hybrid plans.1 These rules answer some long-standing questions and provide more certainty to sponsors of hybrid plans as well as employers considering this type of plan design.

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