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Guest Article

(From the December 20, 2010 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)

IRS Releases Its Priority Guidance Plan

Among the 310 guidance projects that are identified as a priority for the Treasury Department and Internal Revenue Service in their recently-released 2010-2011 Priority Guidance Plan, numerous items relate to employee benefits, including guidance on employer-provided cell phones, new Code § 162(m)(6) that disallows certain health insurance providers from deducting compensation over $500,000, the application of "normal retirement age" to governmental plans, and model language on Code § 83(b) elections.

As explained in the release, the Priority Guidance Plan is flexible and is expected to be updated and republished as this year (i.e., the period from July 2010 through June 2011) progresses, in order to incorporate additional items that may become a priority. As released on December 7, 2010, the plan includes the following items:

Retirement Plans

ERISA § 101(j) - Notice requirements applicable to single-employer plans that become subject to funding-based benefit limitations, as added by the Pension Protection Act of 2006
§ 401(a) - Cumulative list of changes in the requirements for § 401(a) plans
§ 401(k) & (m) - Final regulations on suspension or reduction of safe harbor contributions (Proposed regulations were published on May 18, 2009.)
§ 403(b) - Plan terminations
§ 403(b) - Prototype programs
§§ 409 & 4975 - Rules applicable to ESOPs
§ 409(l) - Definition of readily tradable securities for ESOPs
§ 414(d) - Governmental plan status
§ 414(e) - Procedures for ruling requests for church plans
§ 414(h)(2) - Pick-up arrangements
§ 414(x) - Eligible combined plans
§ 430 - Final regulations on determination of minimum required contributions (proposed regulations were published on April 15, 2008)
§ 431 - Updating revenue procedure on multiemployer plan amortization extension requests
§ 4980F - Notice requirements for certain plan amendments to hybrid plans
§§ 6057, 6058, and 6059 - Compliance with certain reporting requirements
Rev. Rules 81-100 and 2004-67 - Group trusts
Guidance:
- on international tax issues related to retirement plans
- on issues related to lifetime income from retirement plans
- updating Employee Plans Compliance Resolution System
- on application of normal retirement age rules to governmental plans
- on funding relief under the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010

Executive Compensation, Health Care and Other Benefits, and Employment Taxes

§ 45R - Small Employer Health Insurance Credit
§ 83 - Regulations to incorporate the holding in Revenue Ruling 2005-48
§ 83(b) - Model language on elections
§ 125 - Final regulations on cafeteria plans (proposed regulations were published on August 6, 2007)
§ 162(l) - Applicability to COBRA premiums
§ 162(m) - Transition relief under Treas. Reg. § 1.162-27(f)(1)
§ 162(m)(6) - The application of this section as added by the PPACA
§§ 280G and 4999(a) - Change in ownership
§ 409A - Final regulations on income inclusion (proposed regulations were published on December 8, 2008)
§ 409A(b) - The application of this section as amended by the Pension Protection Act
§ 457A - The application of this section as added by §801 of the Tax Extenders and Alternative Minimum Tax Relief Act of 2008
§ 457(f) - Ineligible plans
§ 512 - Regulations explaining how to compute unrelated business taxable income of VEBAs (temporary regulations were issued on January 29, 1986)
§ 1400R - The employee retention credit, as added by the Gulf Opportunity Zone Act of 2005.
§ 3121(z) - Regulations implementing this section as added by §302 of the Heroes Earnings Assistance and Relief Tax Act of 2008, on foreign employers
§§ 3127, 3121(b)(3)(A) and 3306(c)(5) - Regulations making certain FICA exemptions available for disregarded entities
§ 3504 - Regulations designating certain parties who file employment tax returns under their EINs for their clients' workers persons required to perform acts of employers
§ 4980B - Calculation of the applicable premium for COBRA continuation coverage
§ 4980G - Regulations on interaction with §125 with respect to comparable employer contributions to employees' HSAs
§ 6051(a)(14) - Reporting aggregate cost of employer sponsored health coverage
Rev. Rul. 95-7 - Updating guidance on tips
Guidance on employer-provided cell phones as a result of enactment of §2043 of the Small Business Jobs Act of 2010.

The information in this Washington Bulletin is general in nature only and not intended to provide advice or guidance for specific situations.

If you have any questions or need additional information about articles appearing in this or previous versions of Washington Bulletin, please contact:

Robert Davis 202.879.3094, Elizabeth Drigotas 202.879.4985, Mary Jones 202.378.5067, Stephen LaGarde 202.879-5608, Bart Massey 202.220.2104, Tom Pevarnik 202.879.5314, Sandra Rolitsky 202.220.2025, Deborah Walker 202.879.4955.

BenefitsLink is an independent national employee benefits information provider, not formally affiliated with the firms and companies who kindly provide much of the content and advertisements published on this Web site, including the article shown above.