2011-2012 Priority Guidance Plan Released
On September 2, 2011, the IRS and Department of Treasury jointly released their 2011-2012 Priority Guidance Plan
which lists those projects the IRS intends to provide guidance on throughout the plan year from July 2011 through June 2012. A variety of issues will be addressed, including those that will impact governmental plans and employers. Ice Miller will be monitoring those developments that are of interest to governmental plans, particularly the following items under the Employee Benefits - Retirement Benefits heading of the Guidance Plan:
#1 (exceptions to additional tax under Internal Revenue Code (Code) Section 72(t) on early distributions); #2 (cumulative list of changes for Code Section 401(a) plans); #5 (final regulations under Code Section 402(a)); #8 (guidance on Code Section 403(b) plans); #15 (guidance on governmental plan status under Code Section 414(d)); #17 (guidance on pick-up arrangements under Code Section 414(h)(2)); and #29-34 (updates to Revenue Procedure 2005-16, updates to Revenue Procedure 2007-44, guidance on group trusts under Revenue Rulings 81-100 and 2011-1, guidance on rollovers to defined benefit plans, updates to the Employee Plans Compliance Resolution System, and guidance on application
of normal retirement age rules to governmental plans).
For additional information about the 2011-2012 Priority Guidance Plan, please contact Mary Beth Braitman,
Terry A.M. Mumford, Katrina M. Clingerman,
Lisa E. Harrison, or the Ice Miller LLP Employee Benefits attorney with whom you work.