Brief Case
Pension Resource

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Resource Collections

Employee Plans News - Special Edition Auguest 2007

Requirements for “Separate Agreements” for §412(i) Pension Plans. Starts on page 2.

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Employee Plans News - Spring 2007

Resolution Possibility for Plans in 412(i) Audit Program. Starts on page 14.

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Employee Plans News - Summer 2007

412(i) Plans: Requirements for Retroactive Funding Standard. Starts on page 11.

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Memorandum for Director, EP Examinations

Corrective Amendments to Pre-Approved Plans for 412(i) plans.

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Rev. Rul. 2004-20

Excess Life Insurnce in a 412(i) Plan

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Treasury Inspector General for Tax Administration

Penalty Cases for Failure to Disclose Reportable Transactions Were Not Always Fully Developed

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IRS Summer 2013 CPE for Floor-offset Arrangements

As released in 2013, this resource provides a comprehensive review of floor-offset plan designs. References, exhibits, and examples are included. Besides a plan document, this is a great resource.

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IRS Memo 201810008 for CB Offset

As release in February 2018, this covers two issues for floor-offset arrangement: broadly available separate plans and prior benefit structure for 401(a)(26).

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Opinion Letter 201501025 Freeze

Release in 2015, this opinion letter covers qualification concerns for freezing a floor-offset. In particular if benefits can be frozen as of that date but have growing DC balances.

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Revenue Ruling 76-256

This ruling provides the general option and the minimum requirements to have a floor-offset DB-DC plan design.

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Rev. Proc. 2015-36

For preapproved cash balance plans, Section 6.03(7)(g) provides the requirements for offsetting hypothetical accounts.

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IRS Phone Form 2010

In this IRS phone form on page 5, they state their position on vested benefits used in a floor offset arrangement.

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IRS Chapter 3 - Retirement Plan Compensation

A general resource for retirement plan compensation definitions, references, exhibits, and examples are included. 415, 414s), 403(b), and other helpful compensation details are included.

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IRS Sole Proprietor Earned Income

Updated 2021, this detailed article provides the details and references on calculating earned income for retirement plans.

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IRS Self-Employed Individuals – REI Examples

A couple of examples of calculating reduced earned income plus the i/(1+i) shortcut.

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IRS Memo 0305007 Earned Income and Royalties

Royalties, depending on facts and circunstances, may be included as income for retirement plan purposes. This memo provides references to review.

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