Headlines about "Ret plans - amendments required, incl. EGTRRA"
Gathered from the web by the editors at BenefitsLink.com.
[Guidance Overview] Final 403(b) Regulations Make 2008 a Key Planning Year
Excerpt: "This article focuses on a number of significant changes and trends reflected in the final §403(b) regulations and related guidance that impact plan design and implementation decisions that should be made in 2008." (Groom Law Group)
[Opinion] American Society of Pension Professionals & Actuaries' Comments on EPCRS Provisions That Apply to Retroactive Plan Amendments (PDF)
Excerpt: "On April 25, 2008, ASPPA submitted a comment letter to the IRS and Treasury discussing current methods available to plan sponsors through EPCRS to retroactively correct certain document errors, and providing additional examples to assist plan sponsor and practitioners." (American Society of Pension Professionals & Actuaries)
TIAA-CREF Publishes 403(b) Guide for Plan Sponsors
Excerpt: "TIAA-CREF has released a guide to new 403(b) regulations. A news release said the publication, '403(b) Plan Fundamentals - Your Guide to Compliance,' includes: At a Glance - An overview of new rules, plan sponsors' responsibilities, and a checklist for compliance; The Details - In-depth information about plan documents, non-discrimination requirements, loans and distributions, information sharing agreements, plan documents, contribution limits, Form 5500 and the Employee Retirement Income Security Act (ERISA), and fiduciary liability; and Resources – Frequently Asked Questions, a glossary, and reference materials.' (PLANSPONSOR.com; free registration required)
[Guidance Overview] Employee Plans Compliance Resolution System Update Expected 'Soon'
Excerpt: "An updated version of Rev. Proc. 2006-27 . . . will not be a major overhaul of the old procedure, . . . but will contain a number of smaller changes that taken together will have a significant effect on the program." (Wolters Kluwer)
[Guidance Overview] IRS Proposes Amendments to 204(h) Rules
Excerpt: "The IRS proposed a number of changes to the participant advance notice requirements under Section 204(h) of ERISA that are required for certain pension plan amendments." (Towers Perrin)
[Guidance Overview] IRS Provides Timeline for Adoption of Certain Pre-Approved EGTRRA Plan Documents (PDF)
2 pages. Excerpt: "On March 31, 2008, the IRS issued opinion and advisory letters for most prototype and volume submitter defined contribution plans that were restated to comply with the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA)." (Prudential Retirement)
Small Change in Pension Bill Could Make a Big Dollar Difference
Excerpt: "The House and Senate are trying to settle on a final bill for technical corrections to the Pension Protection Act. Most are minor, but one drawing fire centers on an accounting technique called smoothing." (Workforce Management; free registration required)
[Guidance Overview] Important Update on EGTRRA Restatements
Excerpt: "Employers who are entitled to use the 6-year cycle for pre-approved defined contribution plans must restate their plans by April 30, 2010 (See IRS Announcement 2008-23). This is also the date by which such employers need to submit their plans for determination letters, if desired. The submission of pre-approved plans is generally made using Form 5307." (SunGard Corbel LLC)
[Guidance Overview] Notice 2008-30 - Guidance on PPA Changes to Distribution Rules for 2008
Excerpt: "Notice 2008-30 provides guidance on distribution-related provisions of the Pension Protection Act of 2006 (PPA) that are effective in 2008, including rollovers from eligible retirement plans to Roth IRAs, additional survivor annuity options, and interest rate assumptions for lump sum distributions. The notice also provides guidance regarding plan amendments for certain gap-period earnings." (McKay Hochman Co., Inc.)
Defined Benefit Notice Suit Survives Challenge
Excerpt: "A federal judge in Texas has ruled that the statute of limitations clock has not expired for defined benefit plan participants' assertions relating to the required plan amendment notice." (PLANSPONSOR.com; free registration required)
[Guidance Overview] Chart of New Multiemployer Plan Disclosures and Communications Required by Pension Protection Act of 2006 (PDF)
1 page. Excerpt: "The Pension Protection Act of 2006 (PPA) requires multiemployer pension plans to make a number of significant new disclosures to plan participants and beneficiaries, employee representatives, unions, employers, and regulators such as the IRS, the Department of Labor (DOL), and the PBGC. This 2008 Disclosure and Communications Calendar can help you get these important new notices out on time and on target." (Milliman)
[Guidance Overview] Listing of IRS Published Guidance for January - March 2008
The target page links to guidance published by the Service relating to retirement plans: Treasury Regulations; Revenue Rulings; Revenue Procedures; Notices; and, Announcements. (Internal Revenue Service)
[Guidance Overview] New 403(b) Regulations
Excerpt: "The complicated 403(b) market needed updating in order to be more easily managed by both school districts and the IRS. Since 1964, the 403(b) rules had been updated but had not gone through a complete overhaul. In July 2007, the IRS finalized the first comprehensive 403(b) regulations in 43 years. These new rules require a written plan that will standardize each district's 403(b) providers. While providers and employers have until Jan. 1, 2009, to be fully compliant, the changes have already begun." (Financial Planning)
[Guidance Overview] IRS Expected to Issue Opinion Letters and Advisory Letters to Document Providers Who Timely Filed Their Plan Documents for EGTRRA (PDF)
1 page. Excerpt: "The Internal Revenue Service (IRS) has issued Announcement 2008-23 relating to the issuance of Opinion and Advisory Letters and the opening of the EGTRRA determination letter program for IRS pre-approved defined contribution plans. This Announcement affects document providers of pre-approved defined contribution plans and plan sponsors using one of these plans." (Transamerica Center for Retirement Studies)
[Guidance Overview] Employee Plans News, Spring 2008 (PDF)
16 pages. Excerpt: "This edition includes articles such as Recent Guidance that May Require Interim or Discretionary Amendments; Determination Letters Coming Your Way; Steve Miller Discusses Governmental Plans Roundtable; New PPA Guidance; Exam's Risk Modeling Project; Economic Stimulus Payments; Written Plan Requirement for 403(b) Plans; 'Interesting' Pension Guidance Issued; and AFTAP Certifications." (Internal Revenue Service)
[Guidance Overview] IRS Date for Issuing Letters on Pre-Approved Plans, Schedule for Plan Adoptions, and Details for Submissions
Excerpt: "EBIA Comment: Many employers use pre-approved plan documents for their qualified retirement plans, including 401(k) plans. While these documents can limit employers' flexibility in setting plan terms, they are inexpensive and may offer other advantages, such as eliminating the need for individual determination letter submissions. Following the IRS's release of the pre-approved plan opinion and advisory letters, affected employers will finally be able to adopt EGTRRA-approved restatements and, if they choose, submit their restated plans for individual determination letters." (Employee Benefits Institute of America)
[Guidance Overview] IRS/Treasury Proposed Regulations Concerning Notice Required for Pension Plan Amendments
Excerpt: "The Treasury Department and Internal Revenue Service have issued proposed regulations that would provide guidance concerning application of the notice requirements of Code Sec. 4980F and section 204(h) of ERISA to a plan amendment that is permitted to reduce benefits accrued before its applicable amendment date. The proposed regulations would impact pension plan sponsors, administrators, participants and beneficiaries." (CCH Incorporated)
Hewitt Survey Shows Plan Funding and Employee Participation Will Be Focus in 2008
Excerpt: "Hewitt's study of 190 mid- to large-sized U.S. companies revealed that new funding rules for pensions and increased scrutiny of retirement plan operations are prompting more companies to administer their defined benefit plans with an eye to reducing plan risk of underfunding due to investment losses in 2008." (Wolters Kluwer)
Retirement Plan Sponsors to Focus on Risk Management, Automation, Employee Accountability in 2008
Excerpt: "Hewitt's study of 190 midsize and large U.S. companies revealed that the new funding rules for pension plans enacted by the Pension Protection Act of 2006 (PPA) and increased scrutiny of retirement plan operations in general are prompting more companies to take additional steps to administer their plans within a risk framework in 2008." (Wolters Kluwer)
[Official Guidance] Text of Proposed IRS Regs: Requirements for Certain Pension Plan Amendments Significantly Reducing the Rate of Future Benefit Accrual (PDF)
26 pages. Excerpt: "Section 4980F sets forth the requirements for providing notice to certain affected persons when a plan significantly reduces future benefit accruals. A notice required under section 4980F of the Code or the parallel rules in section 204(h) of [ERISA] is referred to as a 'section 204(h) notice.' These proposed regulations would set forth timing rules for providing a section 204(h) notice for a plan amendment that is permitted to be effective before the applicable amendment date. In addition, the regulations provide guidance relating to changes made in section 4980F by the Pension Protection Act of 2006 . . . ." (Internal Revenue Service)
[Guidance Overview] Employee Benefits & Executive Compensation Webinar on PPA Compliance
Excerpt: "On March 6, Drinker Biddle and Watson Wyatt Worldwide presented a webinar on how plan sponsors will comply with the Pension Protection Act of 2006 (PPA), and how they will face the monumental task of implementing the PPA requirements in 2008. . . . [The target page has a link to view the presentation as well as hear the audio portion of this webinar.]" (Drinker Biddle & Reath LLP)
[Guidance Overview] House Passes PPA Technical Corrections Bill
Excerpt: "The U.S. House of Representatives late on March 12, 2008 passed a bill (H.R. 3361) to make a series of 'technical' corrections to the Pension Protection Act ('PPA') of 2006 (P.L. 109-280). The House-passed bill differs slightly from a PPA technical corrections bill (S. 1974) the Senate approved in December 2007. That means the House and Senate bills will need to be reconciled, a process expected to begin in April." (Deloitte via BenefitsLink.com)
[Guidance Overview] IRS May Have Ended Form 5307 Roulette with Announcement 2008-23
Excerpt: "The IRS . . . announced some important changes to when Form 5300 should be filed instead of Form 5307 by a plan using a prototype or volume submitter plan document, and which Cumulative List will be used to review a prototype or volume submitter plan document filed using Form 5300." (Pension Protection Act Blog)
[Guidance Overview] New Federal Regulations for 401(k) and Other Defined Contribution Plans (PDF)
2 pages. (Milliman)
[Guidance Overview] PPA Check Up
Excerpt: "In this article, we review strategic decisions confronting, and critical choices available to, plan sponsors in complying with new PPA rules generally and the benefit restriction certification requirements specifically." (JPMorgan)
[Official Guidance] IRS Announcement 2008-23: IRS to Begin Issuing Letters for M&P Plans Filed for Approval of EGTRRA Changes (PDF)
4 pages. Announcement 2008-23 states that the Service will soon issue opinion and advisory letters for pre-approved master and prototype and volume submitter defined contribution plans that were timely filed with the Service to comply with the Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107-16, and other changes in plan qualification requirements listed in Notice 2004-84, 2004-2 C.B. 1030. (Internal Revenue Service)
[Opinion] American Benefits Council Letter Urging Asset Smoothing Clarification with PPA Technical Corrections (PDF)
2 pages. Excerpt: "I am writing on behalf of the members of the American Benefits Council (Council) regarding legislation to clarify the 'asset smoothing' rules for defined benefit pension plan funding, since such legislation may be considered with the Pension Protection Act of 2006 (PPA) technical correction bill (H.R. 3361) this week." (American Benefits Council)
Text of Pension Protection Technical Corrections Act, H.R. 3361 (PDF)
54 pages. (U.S. House of Representatives via American Benefits Council)
House Ways and Means Committee Description of the Pension Protection Technical Corrections Act, H.R. 3361 (PDF)
19 pages. (U.S. House Wasy and Means Committee via American Benefits Council)
March 11, 2008 Issue of IRS 'Employee Plans Bulletin' -- Info About Governmental Plans Roundtable (PDF)
1 page. Describes a meeting on April 22 in Washington; space is limited to 52 participants. (Internal Revenue Service)
[Official Guidance] Text of IRS Notice 2008-30: Certain Disribution-Related Provisions of PPA That Are Effective in 2008 (PDF)
10 pages. Excerpt: "This notice [provides] guidance on amending plans to require that distribution of excess deferrals includes earnings from the end of the taxable year to the date of distribution ('gap-period' earnings). . . . The sections of PPA '06 addressed in this notice are § 824 (relating to rollovers from eligible retirement plans to Roth IRAs), § 1004 (relating to additional survivor annuity options), and § 302 (relating to interest rate assumptions for lump sum distributions)." (Internal Revenue Service)
[Guidance Overview] Handling by Retirement Plans of Post-Severance Payments: Action Needed (PDF)
3 pages. Excerpt: "The Treasury Department issued revised final regulations under § 415, which new rules are effective for plan years beginning on and after January 1, 2008. (For non-calendar plan years, the regulations are effective for years beginning on or after July 1, 2007.) . . . . For 401(k), 457(b) and 403(b) plans that allow employees to direct some of their pay into plans, the new rule means that amounts paid after employment terminates may not be deferred and contributed, even if it is W-2 pay, unless an exception applies (see below)." (The ERISA Law Group, P.A.)
[Official Guidance] From IRS: 'Retirement News for Employers' Winter 2008 Edition (PDF)
Excerpt: "How Much Can You Deduct in Your Retirement Plan?; We're Glad You Asked!; New of the Web; Keeping Your Plan in Compliance; Using a Plan Amendment for Correction in the Self-Correction Program; Recent Guidance; The Filing Cabinet; IRS Employee Plans Videos - Now Available Online" (Internal Revenue Service)
[Guidance Overview] Discussion of PPA Funding-Related Effective Dates as Revised by IRS Notice 2008-21
Excellent. (JPMorgan)
Video from IRS: Fixing Plan Mistakes Found During an IRS Audit
Directed to employers. Excerpt: "IRS EP Examinations Director discusses what happens when EP Agents find mistakes while examining retirement plans.' (4:45 min.) (Internal Revenue Service)
[Guidance Overview] IRS Updates Proposed Effective Date for Certain PPA Funding Regulations
Excerpt: "For employers who choose not to follow the relevant proposed regulations for 2008 plan years, the notice provides certain specific guidelines on what will constitute a 'reasonable interpretation' of the PPA statutory provisions. The notice also provides a special transition rule for applying the PPA benefit restrictions to small plans that use the last day of the plan year as the valuation date for each of the plan years beginning in 2006, 2007, and 2008." (Deloitte via BenefitsLink.com)
[Guidance Overview] IRS Delays Effective Date of Regs on Funding and Benefit Restrictions for Single-Employer Pension Plans
Excerpt: "The delay in the effective date of the regulations and the opportunity to use a reasonable interpretation of the law is welcome. This is especially true for the benefit restriction rules, which would be difficult to administer following the detailed requirements of the proposed regulations." (The Segal Group, Inc.)
[Guidance Overview] Qualified Retirement Plans - Cycle C Applications Accepted Beginning February 1, 2008
Excerpt: "Effective February 1, 2008, IRS will begin accepting determination letter applications for Cycle C qualified retirement plans. Cycle C plans are individually-designed plans that are sponsored by an employer with an EIN ending in 3 or 8. Governmental plans – including governmental multiemployer and multiple employer plans – are also Cycle C plans." (Deloitte via BenefitsLink.com)
[Guidance Overview] Employee Benefits as of January 24, 2008 (PDF)
5 pages. This edition includes: A Look at ERISA Litigation: Preemption of San Francisco's Health Reform Law; Qualified Plan Queries: IRS Informally Indicates No Redlining of Plans Required for Cycle B Submissions; EEOC Regulations Resolving the Erie County Issue; Exec Comp Corner: SEC Comments on Year 1 Compensation Disclosures; and, Payroll Tax & Fringe Benefit Pointers: Reporting Settlement Payments to Claimants and Their Law Firms. (Miller & Chevalier Chartered)
[Guidance Overview] Pomeroy Letter to Treasury on Clarification of PPA Funding Regulations (PDF)
2 pages. Excerpt: "On January 18, 2008, Rep. Earl Pomeroy (D-ND) sent a letter to Treasury Secretary Henry M. Paulson asking for clarification that a 'reasonable interpretation' of PPA is permitted until funding regulations become effective." (Earl Pomeroy via American Society of Pension Professionals & Actuaries)
[Guidance Overview] Single-Employer Funding Rules Under PPA
Excerpt: "In this article, we review the single-employer funding rules under PPA, reflecting regulatory guidance through December 2007. This article does not cover special issues for hybrid plans . . . ." (JPMorgan)
IRS Puts out Revised Application for Plan Qualification
Excerpt: "The Internal Revenue Service (IRS) has announced a new version of Form 4461-A, 'Application for Approval of Master or Prototype or Volume Submitter Defined Benefit Plan,' has been released and is now available online." (PLANSPONSOR.com; free registration required)
[Official Guidance] New FAQs from IRS Elaborate on 'Cycle-Changing Events' for Determination Letter Program
Other new questions appear under the 'Miscellaneous' heading (questions 10 through 12). BenefitsLink thanks attorney Tom Farnam of St. Louis and Alexandria VA for the link! (Internal Revenue Service)
[Official Guidance] IRS 'Employee Plan News' Announcing Revised Forms for M&P Applications, Reminder re Cycle B Submission Deadline (PDF)
Excerpt: "This special edition announces that Forms 4461-A, 5329, and 5558 have been revised and are available. Form 5330 is currently being revised. In addition, this special edition reminds you that the Cycle B submission period for determination applications ends January 31, 2008 and Cycle C begins February 1, 2008. Proposed cash balance regulations and section 430 proposed regulations were issued on December 28, 2007." (Internal Revenue Service)
One Last Look at Cycle B and Looking Ahead to Cycle C
Excerpt: "In a few weeks, on January 31st, Cycle B ends and Cycle C begins. Cycle C marks the middle of this great experiment called the EGTRRA remedial amendment cycle restatement period. Like all experiments, charts and tables come in handy. When the IRS issued Rev. Proc. 2007-44 last year, they also updated the Quality Assurance Bulletin (QAB) on the EGTRRA Staggered Remedial Amendment Period and Remedial Amendment Cycle for Individually Designed Plans, with charts and tables included within the QAB." (Pension Protection Act Blog)
Overview: Cumulative List -- IRS Notice 2007- 94
Excerpt: "The 2007 Cumulative List of regulatory changes is basically for Cycle C plans. Cycle C plans are individually designed plans whose EIN ends in 8 or 3 and whose filing timeframe is February 1, 2008 to January 31, 2009. This is the first cumulative list after the updated Rev Proc 2007-44 (that updated Rev Proc 2005-66). Once again the IRS has listed as 'new', items that appear for the first time." (McKay Hochman Co., Inc.)
Overview: 415 Final Regulations Plan Amendment
Excerpt: "The §415 changes will have to be done by separate amendment even if executed simultaneously with the EGTRRA restatement. In fact, depending on timing, the §415 amendment may need to be attached to both the employer's GUST and EGTRRA documents." (McKay Hochman Co., Inc.)
2008 Compliance Calendar Checklist for DB/DC/403(b) Plans
Excerpt: "Certain provisions of the Pension Protection Act of 2006 will require plan amendments. Plan amendments should be effective retroactively and will not violate anti-cutback rules if made on or before the last day of the plan year beginning on or after January 1, 2009 (or 2011 for governmental plans)." (PLANSPONSOR.com; free registration required)
A Comprehensive Outline of Deadlines for Interim and Discretionary Amendments, as of January 4, 2008
Excerpt: "These amendment deadlines include: non-spouse beneficiary rollovers; the Final Regulations under Code §415; the Heinz Decision; the modification to the applicable mortality table and applicable interest rate under Code §417(e); the Final Regulations relating to Normal Retirement Age under Regulation §1.401(a)-1; the elimination of gap period income on excess contributions and/or excess aggregate contributions . . . ." (AccuDraft)
Overview of the IRS 2007 Cumulative List (PDF)
Pages 6-8 of 9 pages. Excerpt: "In general, the Cumulative List identifies the changes in qualification requirements that must be taken into account and that are required to be incorporated into the plan document when an application for an opinion, advisory or determination letter is submitted and reviewed by the IRS. The 2007 Cumulative List contains all of the changes in statutes, regulations and guidance that have become effective since December 31, 2001." (Trucker Huss)
Technical Corrections Bill Not Acted Upon by Congress; New Funding Rules Are Effective 1/1/2008 Without Guidance from the IRS
Excerpt: "Last night, Congress adjoined without acting on H.R. 3361, the House of Representative's version of the Pension Protection Technical Corrections Act of 2007. The Senate passed S. 1974, the Senate version of the Pension Protection Technical Corrections Act of 2007. The House could still pass their version of the bill after the holiday recess but it will not be in time to delay PPA's new funding rules for defined benefit plans." (Pension Protection Act Blog)
Principal Unveils Comprehensive Education Program to Help Non-Profits and Financial Professionals with Complex 403(b) Rule Changes
Excerpt: "To help financial professionals and their clients navigate this major transition, The Principal--which provides services to 4,885 non-profit plans, covering nearly 550,000 participants(1) --has created a comprehensive program. In addition to providing support to help comply with the new requirements, The Principal is offering two white papers and an easy-to-use guide that summarize the regulations and provide analysis of their implications . . . ." (Business Wire via The News & Observer Publishing Company)
Additional Important Opportunity for Practitioners to Suggest Improvements to the Employee Plans Compliance Resolution System (EPCRS)
Attorneys, consultants, third-party administrators and other retirement plan practitioners dealing with IRS audits of retirement plans: please take time to compose and submit your recommendations as to how the Employee Plans Compliance Resolution System (EPCRS) could be improved. These recommendations are being collected by a committee selected by the IRS, for an important report that will help the Treasury Department and IRS comply with Congress' directive under the Pension Protection Act of 2006 to assess and possibly modify the program. The link will take you to an online form, or you can submit your comments in the form of an emailed Word document. Thank you! (The committee requested and received practitioners' comments in October, but would like to receive even more.) (IRS Advisory Committee (ACT) on Tax Exempt and Government Entities)
Overview: Plan Sponsor Considerations for the New Year
Excerpt: "[Plan sponsors should have a list] to consider - the list of changes to plans effective for the new year. This issue of Fast Focus is a summary list of key provisions from the Pension Protection Act of 2006 (PPA) and other laws affecting defined contribution plans and defined benefit plans." (Chang Ruthenberg and Long PC)
Overview: 2007 Cumulative List of Changes in Plan Qualification Requirements for Cycle C Plans
Excerpt: "The IRS publishes an annual cumulative list to identify statutory, regulatory, and guidance changes that plan sponsors must take into account in their submissions for opinion, advisory, and determination letters of plans whose remedial amendment period begins on the February 1 following issuance of the cumulative list. The IRS has now released the 2007 Cumulative List, which will be used primarily by plan sponsors of individually designed plans that are in Cycle C of the remedial amendment cycle. (Generally, a plan is in Cycle C if the last digit of the plan sponsor's EIN is 3 or 8; certain governmental plans also are in Cycle C.)" (Employee Benefits Institute of America)
Notice 2007-94 Provisions on Guidance Cutoffs Mean Cycle C Plan Document Revisions Can Be Completed and Ready in February 2008
Excerpt: "The 2007 Cumulative List states that, when reviewing Cycle C plans, the IRS will not consider guidance issued after October 1, 2007. . . . This means my Cycle C plan documents can be completed and ready in February, at the beginning of Cycle C, because this year [unlike the rules for Cycle B plans in 2006] there is no further guidance to wait for." (Pension Protection Act Blog)
Does Your Qualified Retirement Plan Need to Be Amended This Month? (PDF)
4 pages. Excerpt: "Recent IRS guidance has reminded plan sponsors of deadlines for amending qualified retirement plans. Some amendments must be completed by December 31, 2007 (for calendar-year plans). Others must be completed by January 31, 2008 (for Cycle B plans). Still others must be completed by the deadline for filing the plan sponsor's 2007 tax return ('interim' amendments). This advisory identifies those plans that must be amended now or in the near future." (Alston & Bird LLP)
November 30, 2007 Special Edition of 'Employee Plans News' from IRS (PDF)
2 pages. Contains links to documents published on BenefitsLink last week; no analysis or additional details are included in this IRS publication. Excerpt: "This Special Edition announces Revenue Procedure 2007-71 which provides model plan language that may be used by public schools to either adopt a written §403(b) plan or to amend its §403(b) plan to reflect the requirements of the Internal Revenue Code and final 403(b) regulations. Also, the 2007 Cumulative List is published." (Internal Revenue Service)
Overview: IRS Publishes 403(b) Model Plan, Orphan Contract Guidance (PDF)
4-page summary. (Sutherland Asbill & Brennan LLP)
IRS Notice 2007-94: 2007 Cumulative List of Changes in Plan Qualification Requirements (PDF)
Excerpt: "The 2007 Cumulative List is to be used primarily by plan sponsors of individually designed plans that are in Cycle C. An individually designed plan is in Cycle C if it is a single employer plan where the last digit of the employer identification number of the plan sponsor is 3 or 8, or it is a § 414(d) governmental plan (including a governmental multiemployer plan or governmental multiple employer plan)." (Internal Revenue Service)
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