The Internal Revenue Service issued Notice 2014-19 and a set of Frequently Asked Questions on April 4, 2014, clarifying certain retroactive retirement plan implications of the Supreme Court’s Windsor ruling. The guidance requires plans to be administered to reflect the Windsorruling effective as of June 26, 2013, but does not require plans to retroactively recognize same-sex spouses prior to that date. In addition, the IRS clarified the requirements for any Windsor-related plan amendments.
IRS Guidance Clarifies Retroactive Retirement Plan Impact of Supreme Court’s Windsor Ruling
By Brian Tiemann and Todd Solomon on April 15, 2014
Posted In Retirement Plans
Brian TiemannBrian J. Tiemann counsels public and private companies on a broad range of employee benefit matters, including matters related to pension plans, 401(k) plans and executive and incentive compensation. He advises plan fiduciaries with respect to their fiduciary duties, investment policies and alternative investments. He also advises multinational clients on global employee benefits matters, particularly with respect to global incentive compensation plans. Brian has extensive experience negotiating investment management agreements and service provider agreements. Read Brian Tiemann's full bio.
Todd SolomonTodd A. Solomon focuses his practice on designing, amending and administering pension, profit sharing, 401(k), employee stock ownership and 403(b) plans, as well as nonqualified deferred compensation arrangements. He also counsels privately and publicly held corporations and tax-exempt entities regarding fiduciary issues under the Employee Retirement Income Security Act (ERISA), employee benefits issues involved in corporate transactions, executive compensation matters and the implementation of benefit programs for domestic partners of employees.Read Todd A. Solomon's full bio.
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