"A federal district court recently granted an employer's motion to dismiss a claim for benefits on the ground that the satisfaction of annuity benefits under a nonqualified retirement plan with a lump sum payment does not adversely affect a participant's benefit.... [T]he employer terminated its nonqualified retirement plan and replaced the participant's monthly benefit payable as a joint and survivor annuity with a single, actuarial equivalent lump sum payment. In its decision, the court agreed with the employer that the tax consequences of benefit payments are not part of the accrued benefit protected by ERISA." [Taylor v. NCR Corp., No. 1:14-cv-2217-WSD (N.D. Ga. Sept. 23, 2015)]