The IRS Backtracks on Retiree Lump Sum Window Prohibition; Some Concerns Remain
Is it time to consider if a retiree lump sum window is appropriate for your company?
The Internal Revenue Service made a change in direction from its earlier guidance regarding retiree lump sum windows. In the recent Notice 2019-18 no regulatory amendments are expected to block retiree lump sum windows for defined pension plans. This white paper provides background on the earlier notice and the discusses the retraction of intent to amend regulations.
Attorney in the Troy, Michigan office of Dickinson Wright
Practice emphasizes all aspects of employee benefits and executive compensation law, including qualified retirement plans, welfare plans, and nonqualified compensation programs
Conducts regular seminars and workshops on numerous employee benefits issues such as ERISA compliance and best practices, avoiding litigation risk for sponsors of retirement plans, and employer fiduciary duties under ERISA
Author of several publications related to employee benefits such as Surviving an IRS or DOL Retirement Plan Audit: Failing to Prepare is Preparing to Fail, Here Comes the Department of Labor: Retirement Plan Audits Begin for Code Section 401(a)(9) Compliance, and Missing Participants Policy and Procedure
Awards include Up and Coming Lawyer, Chambers USA 2020 – present; Best Lawyers in America, Employee Benefits (ERISA) Law, 2023; Michigan Super Lawyers Rising Star, 2016 – present; Michigan Lawyers Weekly, Up & Coming Lawyers, Class of 2017; DBusiness Magazine Top Lawyer, Employee Benefits Law, 2016 – present
Past chair of State Bar of Michigan Taxation Section’s Employee Benefits Committee and past chair of Oakland County Bar Association Employee Benefits Committee
Taxation Council Member, State Bar of Michigan Taxation Section
LL.M. degree in taxation, certificate in employee benefits law, Georgetown University Law Center; J.D. degree, Wayne State University; B.A. degree in political theory and constitutional democracy, Phi Beta Kappa, Michigan State University, James Madison College