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Rehiring Terminated Employees by the End of the 2020 Plan Year May Help Avoid a Partial Plan Termination
Bond, Schoeneck & King Link to more items from this source
[Guidance Overview]
Aug. 20, 2020

"In [a recent set of Q&As], the IRS stated that an employee who was terminated due to the impact of COVID-19, and is rehired prior to the end of the 2020 plan year, generally should not be treated as having suffered an employer-initiated severance from employment when determining whether a partial termination has occurred. While the IRS' position is not a surprising result, it does provide plan sponsors facing rehire decisions with additional clarity regarding how rehires will impact the partial termination analysis."

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