"Were a plan terminating a defined benefit plan and addressing the issue of checks uncashed by missing participants to follow the PBGC's guidance, it would remit the full benefit amount to the PBGC and then seek a refund from the IRS of the taxes erroneously withheld.... [T]he PBGC's guidance and Rev. Rul. 2019-19 provide seemingly inconsistent guidance to plan administrators, in at least some missing participant situations. In light of this apparent possible conflict, the Council requests that the PBGC and the IRS address this issue in order to ensure uniformity in agency policy."

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