On May 25, 2005, the IRS published proposed regulations under Section 415 of the Internal Revenue Code dealing with limitations on benefits and contributions for qualified plans. Here are some helpful resources pertaining to the regulations:
- Special Edition of the IRS Employee Plan News with comments by Marty Pippins, Manager of EP Technical Guidance and Quality Assurance
- Highlights of the 415 Regulations featuring more comments from Marty Pippins
- Submit Your Comments on the Proposed Regulations: Deadline is July 25, 2005
Derrin Watson had some interesting things to say about the new regulations at Benefitslink.com in these Q & As 279 and 280. Excerpt:
One of the most fascinating points about these new rules is their proposed effective date. The 415 regs as a whole are proposed to go into effect for limitation years starting in 2007. But we are told that taxpayers can rely on these post-severance compensation rules now. Mr. Marty Pippins, Manager of EP Technical Guidance, is quoted as saying “This portion of the regulations is proposed effective for limitation years beginning on or after January 1, 2005.” This is fascinating because I cannot find that date anywhere in the proposed regulations. But apparently it behooves practitioners to assume the rules are in effect now.
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