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IRS Updates Guidance for COVID-19-Related Bona Fide Rehires
McDermott Will & EmeryLink to more items from this source
Dec. 10, 2021

"According to the IRS, a rehire due to COVID-19-related 'unforeseen circumstances' generally would not disqualify an individual's prior retirement from being considered a bona fide retirement under a defined benefit plan. However, the IRS cautioned that such a rehire cannot include any prearrangement to rehire the individual prior to the individual's retirement. Such a prearrangement still yields a retirement that is not 'bona fide.' "

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