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IRS Clarifies COVID-19 Partial Plan Termination Relief But Questions Remain
Trucker HussLink to more items from this source
[Guidance Overview]
June 9, 2021

"[It] is not clear whether the IRS will allow plan sponsors to rely on the relief if the plan sponsor vested affected participants as a result of a partial plan termination prior to the enactment of the Act.... If the relief must be provided to all affected participants, then the participants who took a distribution will have received an overpayment -- which requires plan sponsors to attempt to recover the overpayments and to contribute any unrecovered amounts to the plan.... The other option is to limit the relief only to those participants who did not take a distribution."

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