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Next Stop: IRS Compliance Checks of Non-Governmental 457(b) Deferred Compensation Plans
Leonard, Street and Deinard
June 26, 2013 "Specific issues of focus include: (a) verifying the deferrals reported as 457(b) relate to an actual 457(b) plan; (b) verify that the employer is eligible to sponsor a 457(b) plan; (c) confirming that participation is limited to a select group of highly compensated employees, managers, directors or officers ...; (d) determining whether the plan includes features not permitted in Top Hat Plans sponsored by tax-exempts, but that are permitted for governmental 457(b) plans, including loans, age 50 catch-ups and Code Section 457(g) trusts; and (e) reviewing unforeseeable emergency distributions.... [I]dentified plans which are out-of-compliance will be subject to audit or in some cases, referral to the Voluntary Correction Programs." MORE >> |
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