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"Rev. Proc. 2026-3 says specifically that IRS will no longer issue PLRs on Section 420 transfers to a Section 401(h) retiree health account. However, the revenue procedure doesn't say IRS won't issue rulings on Section 420 transfers to a life insurance account. It's unclear whether IRS intended to limit its no-rule decision to transfers to a 401(h) account, and if so, what the agency's reason for doing so might be.... Instead of pursuing a Section 420 transfer, some employers might consider terminating their overfunded DB plans to take advantage of advantageous annuity pricing."  MORE >>

18 pages; Rev. Nov. 2025. "The purpose of this publication is to set forth the tax year 2025 requirements for: [1] Using official [IRS] forms to file information returns with the IRS, [2] Preparing acceptable substitutes of the official IRS forms to file information returns with the IRS, and [3] Using official or acceptable substitute forms to furnish information to recipients."  MORE >>

"This latest IRS publication of 'no ruling' areas [Rev. Proc. 2026-3] ... adds section 420 transactions as a 'no rule' area, including where the employer is asking for guidance on the use of the 401(h) account assets that may have involved a section 420 transfer. And Rev. Proc. 2026-3 continues the IRS 'no rule' position on spinoff-termination transactions  ... where less than all of the surplus assets are being spun off[.]"  MORE >>

"[W]hile there may be a small number of these rulings still 'in the pipeline' that may be completed, after that the IRS is unlikely to consider issuing any more. The normal procedure -- where, as in the case of de-risking, there is ongoing demand for more rulings -- is for IRS to issue a Revenue Ruling similar to the previous Private Letter Rulings... The current controversy over de-risking, however, makes it unlikely that IRS will issue such a Revenue Ruling in this case. In at least two states, Connecticut and New York, legislation has been introduced that, if adopted, would significantly restrict de-risking transactions."  MORE >>

"The proposed regulations would apply to tax years beginning on or after January 1, 2026, with final rules expected in early 2027.... The IRS has expressly reserved further rules governing contribution administration, investments, distributions, reporting, and employer contribution programs. As a result, Trump accounts are authorized but not fully operational and stakeholders should expect additional regulatory detail before broader program implementation can proceed."  MORE >>

Rev. Dec. 2025; 85 pages. "This publication gives you the information you need to determine the tax treatment of your pension and annuity income under the General Rule.... The General Rule is one of the two methods used to figure the tax-free part of each annuity payment based on the ratio of your investment in the contract to the total expected return."  MORE >>

"This notice extends for an additional year the transition period provided in Revenue Ruling 2025-4 for States administering paid family and medical leave (PFML) programs and employers participating in such programs with respect to the portion of medical leave benefits a State pays to an individual that is attributable to employer contributions."  MORE >>

"Until plan assets are properly distributed, the IRS generally treats the plan as ongoing -- with continuing compliance, amendment, and filing obligations.... Poorly executed terminations can result in delayed distributions, missed contributions, late Form 5500 filings, and unnecessary fiduciary exposure. This article explains how to properly terminate a 401(k) plan under IRS rules[.]"  MORE >>

"These rules are not new, so it is not clear why there was a need for the [Chief Counsel Memorandum] at this time. The issuance of this CCA might signal that the IRS is beginning to educate auditors on the substantiation rules and the tax consequences of not complying with these rules.... [A frequent question] is whether it is necessary to substantiate very small expenses, such as those in the $5 or less range. Based on this and earlier IRS guidance, the answer from the IRS' perspective is yes."

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"[T]he IRS/Treasury published final rules addressing how employers that fund health and welfare benefits through a VEBA must calculate the VEBA's UBTI.... The final rules largely mirror proposed UBTI rules the IRS issued in 2014... Rev. Proc. 2020-3 [is the] annual listing of areas where the IRS will not consider private letter rulings. Unfortunately, the IRS added to that list a ban on PLRs involving whether the 100% excise tax on reversions applies to transfers of assets between VEBAs and/or 'repurposing' assets within a single VEBA."  MORE >>