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When Does a COVID-19 Furlough or Layoff Trigger a Partial Termination for Your Qualified Plan?
Boutwell Fay LLP Link to more items from this source
[Guidance Overview]
Sept. 14, 2020

"[T]he IRS will not deem a partial termination to have occurred if a plan sponsor is able to rehire terminated employees before the end of 2020.... [An] applicable period is not necessarily one plan year -- it can span across multiple plan years. The IRS Release does mention rehiring before the end of an 'applicable period' but in its example the IRS only refers to rehiring 'by the end of' 2020. There is uncertainty as to what happens if the rehiring takes place in 2021[.]"

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