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Administering Lifetime Income's Joint and Survivor Annuity Rules Requires Understanding of Revenue Ruling 2012-3
The Business of Benefits
[Guidance Overview] Nov. 12, 2019 "[Rev. Rul. 2012-3] is an actuary's dream, with specific, almost painful details outlining the machinations of how the J&S rules apply when making lifetime income payments from a plan which otherwise is designed to avoid this issue.... [F]our of the most basic concerns are addressed by 2012-3: [1] The annuities are investments, not protected plan benefits.... [2] The joint and survivor rules apply only to the elected annuity contract, not to the entire plan-or even to the entire account balance of the participant.... [3] The J&S rules won't apply until the 'annuity starting date.' ... [4] Making the annuity the default method of payment under the plan won't trigger the J&S rules if the participant can elect out of it before the annuity starting date." MORE >> |
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