Internal Revenue Bulletin: 2014-41
October 6, 2014
This notice provides rules for allocating pretax and after-tax amounts among disbursements that are made to multiple destinations from a qualified plan described in § 401(a) of the Internal Revenue Code. These rules also apply to disbursements from a § 403(b) plan or a § 457(b) plan maintained by a governmental employer described in § 457(e)(1)(A) (a “governmental § 457(b) plan”). Section VI of this notice provides transition rules.
Notice 2014–55 expands the application of the permitted change rules for health coverage under a § 125 cafeteria plan and addresses two specific situations in which a § 125 cafeteria plan participant is permitted to revoke his or her election under a § 125 cafeteria plan during a period of coverage.
Final regulations (TD 9505) concerning hybrid defined benefit plans under Code sections 411(a)(13) and 411(b)(5) were published in 2010. These final regulations, which finalize proposed regulations that were also published in 2010, provide additional guidance concerning hybrid defined benefit plans under Code sections 411(a)(13) and 411(b)(5), as well as section 411(b)(1). In particular, these final regulations provide guidance as to the scope of relief under section 411(a)(13)(A), contain a special rule regarding the application of the 133 1/3 percent rule under section 411(b)(1)(B) to hybrid defined benefit plans, provide additional rules regarding the market rate of return limitation under section 411(b)(5)(B)(i), and provide guidance with respect to the plan termination rules of section 411(b)(5)(B)(vi).
These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services provided by individuals to certain health insurance providers. Section 162(m)(6) was enacted as part of the Patient Protection and Affordable Care Act (Public Law 111–148, 124 Stat. 119, 868 (2010))
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