IRS Will No Longer Prohibit Lump Sum Windows

The IRS reversed its previous position that prohibited defined benefit plan sponsors from offering lump payments to terminated participants currently receiving annuity payments.  The IRS announced in Notice 2019-18 that until further guidance is issued it will not assert that a plan amendment providing for a retiree lump sum window program violates Section 401(a)(9) of the Internal Revenue Code.  The Notice also provides that the IRS will evaluate the plan amendment to ensure it satisfies the relevant provisions of the Code. 

Based on this latest development, it appears plan sponsors can offer retiree lump sum windows as a de-risking strategy.

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