Each year, the ABA’s Joint Committee on Employee Benefits (“JCEB”) meets with officials of federal agencies to discuss issues of interest to employee benefits practitioners. The JCEB then posts the question and answer transcripts on its website. The Q & A’s have now been posted for 2006. You can access them here.
There is some really interesting info in these new Q & As. See Q & As 32 and 33 of the IRS session for some Q & As on section 409A. Also, Q & A 34 for the IRS session discusses the recent Quality Assurance Bulletin mentioned in this previous post here and anwers a question regarding exclusion of “on call,” “per diem,” and “temporary” employees from qualified plans.
Please note that the JCEB website provides the following disclaimer:
The questions are submitted by ABA members and the responses are given at a meeting of JCEB and government representatives. The responses reflect the unofficial, individual views of the government participants as of the time of the discussion, and do not necessarily represent agency policy.
Access previous JCEB Q & As here.