By Pension and Benefits Editorial Staff
The IRS has revised the list of areas under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) for which letter rulings or determination letters will not be issued. Lists of areas of nonissuance under the jurisdiction of the Associate Chief Counsel (International) and the Commissioner, Tax Exempt and Government Entities Division (relating to plans or plan amendments), are presented in separate revenue procedures.
Among the items added to the list of issues for which advance rulings will not be issued is (1) whether a program providing a limited period during which certain retirees who are currently receiving lifetime annuity payments from a qualified pension plan may elect to convert their annuities into lump sums that are payable immediately complies with the qualification requirements under Code Sec. 401 and (2) whether a transfer of assets between welfare benefit funds (including VEBAs), or a new or different use of assets of a welfare benefit fund (including a VEBA), results in a reversion to the employer.
The procedures are effective January 2, 2020.
Source: Rev. Proc. 2020-3.
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