"Rev. Proc. 2026-3 says specifically that IRS will no longer issue PLRs on Section 420 transfers to a Section 401(h) retiree health account. However, the revenue procedure doesn't say IRS won't issue rulings on Section 420 transfers to a life insurance account. It's unclear whether IRS intended to limit its no-rule decision to transfers to a 401(h) account, and if so, what the agency's reason for doing so might be.... Instead of pursuing a Section 420 transfer, some employers might consider terminating their overfunded DB plans to take advantage of advantageous annuity pricing."  MORE >>