Determination letters Determination letters for governmental plans don't address pick-ups and excess benefit arrangements Memorandum – Processing of governmental plans determination letter applications with respect to vesting issues PDF (April 30, 2012) Normal retirement age Summary – Guidance under consideration would affect normal retirement age rules for governmental plans and extend the effective date of the 2007 normal retirement age regulations. REG–147310–12, 2016-07 I.R.B. 336 Proposed regulations that would provide rules on determining whether the normal retirement age under a governmental pension plan satisfies IRC Section 401(a) and whether the payment of definitely determinable benefits that commence at the plan’s normal retirement age satisfies these requirements. They would affect governmental pension plans sponsors, administrators and participants. Vesting Memorandum – Processing of governmental plans determination letter applications with respect to vesting issues PDF (April 30, 2012) Possible approaches to governmental plan guidance The IRS and Department of Treasury solicited comments in 2012 on possible standards for determining if a retirement plan is a governmental plan under section 414(d) of the Internal Revenue Code and have announced guidance under consideration that would affect normal retirement age rules and extend the effective date of the 2007 NRA regulations. ANPRM REG-157714-06 PDF, filed with the Federal Register on November 7, 2011 (governmental plans, generally) ANPRM REG-133223-08 PDF, filed with the Federal Register on November 7, 2011 (Indian tribal government plans)
