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What Happens to Participants' COVID-Related Distributions If the Plan Sponsor Chooses Not to Treat Them as Such?
Business of Benefits Link to more items from this source
[Guidance Overview]
June 23, 2020

"IRS and Treasury have taken the position that an employer can choose to whether or not offer CRD distributions from the plan.... It does not appear that the participant has to file a CRD certification with the plan administrator to get this favorable tax treatment, they just have to be able to prove they meet the (newly expanded, thank you!) CRD standards.... The employer does not have to extend the loan limits under the CRD rules, and the IRS has taken the position that the employer does not have to suspend the requirements that loan payments still be made ... [Notice 2020-50] does not specifically address this issue of what happens when an employer fails to suspend, given the mandatory nature of the law."

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