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Hello! I happen to be familiar with IRS Notice 2020-61, which came out today, covering the deferral of 2020 contributions to 1/1/2021 under the CARES Act. I found the Notice to be very confusing, so I thought I would start this thread as a PSA, to give pension actuaries a leg up on understanding this. This post will explain how & what interest rates are to be used in connection with DB contributions originally due during calendar 2020 under Notice 2020-61. Under 2020-61, the CARES Act EIR rule (i.e., contributions are adjusted at the EIR of the plan year containing payment date) applies for payments actually made from January 1, 2020 through midnight on January 1, 2021 (or January 4, 2021 if the provision in the current Senate stimulus bill passes). For contributions that were originally due during calendar 2020 not yet paid by midnight, January 1, 2021, the CARES Act EIR rule expires. What replaces the CARES Act EIR rule (for unpaid amounts from 2020) is a modified version of 430(j); the modifications are that the quarterly & catch-up due dates are moved from calendar 2020 to 1/1/2021, and the quarterly contribution amounts are increased (with the EIR from the plan year they pertain to) to 1/1/2021. So, for example (which is unfortunately not included as a Notice 2020-61 example), say you have a calendar year plan, with a 1/1 valuation date, not subject to quarterly contributions in 2019. Say the 2019 contribution is made on 1/1/2021. To determine whether the 2019 MRC has been met, you must discount the contribution back to 1/1/2019 at the 2021 EIR. If instead, the contribution was made on 12/31/2020, you must discount the contribution back to 1/1/2019 at the 2020 EIR. The following chart is intended to help you walk through examples provided in Q&A 2 through 6: Notice Example Topic: Discounted contributions @ val date Topic: Adjusting QRC with interest to 1/1/21 PY contribution is for EIR used: orig due date to 1/1/21 Why? Payment dates used A-2 Yes 2019 2020 CARES Act EIR rule 12/31/20 A-3 Yes 2019 2020 CARES Act EIR rule 12/31/20 A-5 Yes 2020 2020 CARES Act EIR rule 12/31/20, 6/1/20 A-6 Ex 1a Yes 2020 2020 Expiration of CARES Act EIR rule; modified 430(j) Not paid by 1/1/21 A-6 Ex 1b Yes 2020 2020, then 2020+5% Modified 430(j) 2/15/21 A-6 Ex 2a Yes 2019 2019 Expiration of CARES Act EIR rule; modified 430(j) Not paid by 1/1/21 A-6 Ex 2b Yes 2019 2020 for 12/15/20 payment; 2019 for unpaid at 1/1/21 CARES Act EIR rule; Expiration of CARES Act EIR rule; modified 430(j) 12/15/20, nothing else paid by 1/1/21

Ian, it is clear to the IRS. Following is from page 6 of Notice 2020-50. I don't think the statute completely forecloses an alternate argument, but in the immortal words of Colonel "Bat" Guano, "You're going to have to answer to the Coca-Cola Company." However, any amount described in Q&A-4 of §1.402(c)-2 is not permitted to be treated as a coronavirus-related distribution. Thus, the following amounts are not coronavirus-related distributions: corrective distributions of elective deferrals and employee contributions that are returned to the employee (together with the income allocable thereto) in order to comply with the § 415 limitations, excess elective deferrals under § 402(g), excess contributions under § 401(k), and excess aggregate contributions under § 401(m); loans that are treated as deemed distributions pursuant to § 72(p); dividends paid on applicable employer securities under § 404(k); the costs of current life insurance protection; prohibited allocations that are treated as deemed distributions pursuant to § 409(p); distributions that are permissible withdrawals from an eligible automatic contribution arrangement within the meaning of § 414(w); and distributions of premiums for accident or health insurance under § 1.402(a)-1(e)(1)(i).