News Today

Today's Federal Register is here and contains temporary and proposed regulations under Internal Revenue Code (the "Code") section 382 and provide guidance on whether a loss corporation has an ownership change where a qualified trust described in Code section 401(a)…

Today’s Federal Register is here and contains temporary and proposed regulations under Internal Revenue Code (the “Code”) section 382 and provide guidance on whether a loss corporation has an ownership change where a qualified trust described in Code section 401(a) (a qualified trust) distributes an ownership interest in an entity.

More on the Chao v. Enron Corporation et al. lawsuit filed yesterday . . .

Kirstin Downey for the WashingtonPost reports: “Restitution Sought From Enron Officials.” The article quotes Marc Machiz, a former Labor Department lawyer in charge of pension programs, as stating that “the lawsuit could have ramifications for the “30 to 40″ private lawsuits moving through the courts that allege that executives exhorted workers to buy stock that subsequently fell in value.” The article quotes Mr. Machiz as stating further that workers at many other companies were hurt as badly or almost as badly as at Enron, including those at WorldCom Inc., Global Crossing Ltd., Williams Cos. and Dynegy Inc.

The Associated Press for the Boston Globe reports in this article: “US sues Enron over pension losses: Ex-executives, directors also targeted in attempt to recover millions.”

I am reviewing the DOL Enron complaint filed yesterday and will report on it here shortly. In the meantime, you can read more on the lawsuit here . . .

IRS Reports: 1% of High-Income Americans Pay No Taxes

The Associated Press has this article for Yahoo! News: "More Wealthy People Avoided Taxes." The article refers to this report (which you can access here) recently released by the Internal Revenue Service….

The Associated Press has this article for Yahoo! News: “More Wealthy People Avoided Taxes.” The article refers to this report (which you can access here) recently released by the Internal Revenue Service.

Reports on the Enron case

The following articles report on the Chao v. Enron Corporation case filed today by the Department of Labor: Findlaw.com has this article by Leigh Strope for the Associated Press: "Labor Department Sues Enron Over Pensions." Reuters has this article by…

The following articles report on the Chao v. Enron Corporation case filed today by the Department of Labor:

  • Findlaw.com has this article by Leigh Strope for the Associated Press: “Labor Department Sues Enron Over Pensions.”
  • Reuters has this article by Peter Szekely: “US Sues to Recoup Enron Workers’ Pension.”
  • USAToday reports: “U.S. suing Enron, former execs over pension losses.”
  • Bloomberg.com provides this account: “U.S. Sues Enron, Former Officers Over Pension Losses.”

In this article by the Houston Chronicle–“Enron facing pension lawsuit; Former executives called negligent”–Eric Berger reports that Rep. John Boehner, R-Ohio, chairman of the House Education and Workforce Committee, praised the lawsuit and stated:

“The Department’s action puts corporate executives and pension plan administrators on notice: Take your fiduciary duty to act in the best interests of your workers seriously or the Labor Department will hold you accountable.”

Segal Company Discusses ERISA section 204(h) Final Regulations

The Segal Company has published this article: IRS Issues Final Regulations on ERISA Section 204(h) Notices of Reductions in Future Pension Benefits. The article discusses the final regulations under section 204(h) of ERISA which were issued back in April of…

The Segal Company has published this article: IRS Issues Final Regulations on ERISA Section 204(h) Notices of Reductions in Future Pension Benefits. The article discusses the final regulations under section 204(h) of ERISA which were issued back in April of this year.

FASB Rules on Pension Accounting

Arden Dale for SFGate.com reports FASB ruled yesterday that companies with defined benefit pension plans will for the first time have to issue quarterly financial reports on their plans. Currently, companies are only required to provide financial statements on their…

Arden Dale for SFGate.com reports FASB ruled yesterday that companies with defined benefit pension plans will for the first time have to issue quarterly financial reports on their plans. Currently, companies are only required to provide financial statements on their defined benefit plans once a year. FASB’s decision is expected to become part of new pension disclosure rules that could go into effect as early as the end of this year. Peter Proestakes, FASB’s pension project manager, said the group hopes to have a draft of the new rule out by August.

Today's Federal Register is here. The Secretary of Labor has filed a lawsuit in the federal district court of Houston, Texas against Enron, Kenneth Lay and Jeff Skilling, the Administrative Committee members of Enron's ESOP and 401(k), and members of…

Today’s Federal Register is here.

The Secretary of Labor has filed a lawsuit in the federal district court of Houston, Texas against Enron, Kenneth Lay and Jeff Skilling, the Administrative Committee members of Enron’s ESOP and 401(k), and members of the Board of Directors for Enron. According to the press release issued by the DOL, the suit seeks to recover losses plan participants suffered “due to the mismanagement of two of Enron’s pension plans.” You can view the complaint filed here as well as a Fact Sheet and Chronology of Enron-related DOL Activity, both posted on the DOL’s website here.

The following remarks were made by Secretary of Labor Elaine Chao today in announcing the lawsuit:

We are sending a message to every pension plan officer, director and fiduciary: you have a solemn duty to safeguard your employees? pension assets. If you put those assets in jeopardy through neglect or malfeasance, we will hold you accountable.

Negotiation Tactics for CEO Employment Agreements

There was a very interesting article today on the front page of the Wall Street Journal which CorpLawBlog reports on here: "As Some Decry Lavish CEO Pay, Joe Bachelder Makes It Happen."…

There was a very interesting article today on the front page of the Wall Street Journal which CorpLawBlog reports on here: “As Some Decry Lavish CEO Pay, Joe Bachelder Makes It Happen.

Plan Language Saves the Day for Plan Administration Error

This Western District of North Carolina case provides a lesson in how mistakes can often lead to big problems in the plan administration arena. Thankfully, the court allowed the mistake to be rectified, but not without a great deal of…

This Western District of North Carolina case provides a lesson in how mistakes can often lead to big problems in the plan administration arena. Thankfully, the court allowed the mistake to be rectified, but not without a great deal of legal cost. This article at EBIA Weekly comments on the case.

The case involves the following unfortunate facts:

Mr. Neal was an employee of General Motors and a participant in the GM Plan, for which he designated his wife as the sole beneficiary. They were later divorced. Pursuant to the terms of their divorce, Mr. Neal and his former spouse signed a Qualified Domestic Relations Order (QDRO), which provided that the former spouse (as “Alternate Payee”),would receive 50% of Mr. Neal’s total vested account balance in the GM Plan.

The opinion states that, upon Fidelity’s receipt of the QDRO, “Fidelity failed to remove” the former spouse’s name as sole beneficiary under the GM Plan, which left intact the existing 1992 Beneficiary Form in Fidelity’s database. Accordingly, upon Mr. Neal’s death, Fidelity declared the former spouse to be the sole beneficiary and established a beneficiary account in her name and transferred all of the remaining GM Plan assets into that account. Subsequently, the former spouse requested and received a complete liquidation and withdrawal of the entire balance from that account. Fidelity later, after determining that the former spouse was not the correct beneficiary for a portion of the account, contacted her and later her estate, requesting that the incorrectly disbursed assets be returned.

In holding for GM and Fidelity, allowing recovery of the payment made in error to the former spouse, the court stated:

“Having determined that a federal common law claim of unjust enrichment is appropriate under ERISA when the facts at issue accord with the archetypal unjust enrichment scenario, and its application would further the plan contract while continuing to advance ERISA policy objectives, and found all of these elements to be present in the instant case, the court holds that it is appropriate to fill in the interstitial gaps of ERISA by allowing a federal common law remedy of unjust enrichment to lie.”

Comment: It is interesting to note that there is no mention of whether or not Mr. Neal failed to file a new beneficiary designation form with the Plan as was discussed in a case reported on by EBIA Weekly here which produced a different result. The North Carolina district court seems to focus on a failure by Fidelity to remove the former spouse as sole beneficiary under the Plan and emphasized this language which was contained in the QDRO Approval Guidelines (i.e. QDRO procedures):

“In the event that the [QDRO] contains language divesting the Alternate Payee of all right and interest in the Participant’s account under the Plan or waiving such right and interest (with the exception of the amount awarded under the Order), Fidelity will interpret this language as voiding any beneficiary designation completed by the Participant prior to the issuance of the Order to the extent that the Alternate Payee is named as beneficiary.”