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Church Plan Clarification Act - Are Regs Expected?


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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.

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  • 5 months later...

I am wondering the same thing. Has anyone here heard any further guidance related to the implementation of such transaction? I have a steeple church 401(a) and 403(b) wanting to merge this year.

Anything new to consider?

It's nice to be important, but it's more important to be nice...


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Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



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The IRS is currently very underfunded and short staffed. They are basically only doing the things that people are screaming for. Unfortunately, there isn't a lot of demand for church plan regulations, nor is there any potential revenue issues since churches don't pay taxes.

No revenue implications + no significant demand = no movement

I wouldn't expect anything, any time soon....or really any time at all.

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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