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American Academy of Actuaries Comments to IRS on Potential Improvements in Section 436 Benefit Restriction Rules (PDF)
Pension Committee, American Academy of ActuariesLink to more items from this source
Feb. 5, 2015

"The Pension Committee is generally supportive of the aims of IRC Section 436. However, it is unnecessarily cumbersome in some respects and could be made easier to administer, easing the burden on plan sponsors, without undermining IRC Section 436's goal of protecting the funded status of pension plans and thereby protecting participant benefits. Our comments fall into the following broad categories: [1] Timing Issues; [2] Avoidance of Restrictions; [3] Application of Restrictions; [4] Conflicts with Collective Bargaining Agreements."

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