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Withholding and Reporting Obligations for Re-Issued Distribution Checks
Ice Miller LLP 
[Guidance Overview] Sept. 15, 2025 "Revenue Ruling 2025-15 is consistent with past IRS rulings that have concluded that withholding and reporting obligations apply at the time a distribution check is distributed to the distributee. This is true even if the check is received but not cashed by the distributee (Revenue Ruling 2019-19) or includes an excess payment that the distributee may be obligated to repay later (Revenue Ruling 2002-84).... [A] number of questions remain regarding plan administrators' obligations when plan participants go missing or fail to receive the check." MORE >> |
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