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Showing results for tags 'church plan'.
Found 4 results
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A non-electing church plan wishes to increase normal retirement age for most participants, effective for already accrued benefits. I know the plan is not subject to 411(d)6, so no cutback issue. Any other issues besides potentially upsetting participants?
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A local church sponsors a 403(b)(9) plan offered by the pension board of the denomination. The Plan meets the definition of a church plan for ERISA and IRC purposes. Adoption agreement states that all employees working 20 hours or more per week are eligible to participate. Church did not realize this and has only been allowing employees working 40 hours per week to participate. Can this be corrected by adopting a retroactive amendment changing eligibility to 40 hours per week? IRS fix-it guide says that a failure to operate a 403(b) plan according to the terms of the written plan can be corrected by adopting a retroactive amendment conforming the plan to its operation, but I am unclear whether this would apply to the situation at hand. It just seems too simple.... -
I have a situation in which a church defined benefit pension plan has two participating employers that have been giving participants contributions and have adopted the plan without an official participation agreement. One plan has been operating in the plan since the spring of 2017 and the other since the mid 1980's. I believe SCP might be able to be used for the first issue but VCP for the second. Any thoughts? The employers provide contributions on behalf of participants. -
Does anyone know when, and if, Treasury and/or the IRS are going to issue regulations and/or guidance for new Code Section 414(z), which permits plan-to-plan transfers between church 403(b) and 401(a) plans? In the meantime, can we move ahead based on a reasonable interpretation of the statutory language only? Thanks very much for your help.
