Published
Reductions in force during 2020 that resulted in significant turnover in active retirement plan participation could constitute a partial plan termination that requires 100% vesting of affected employees. The Consolidated Appropriations Act of 2021 temporarily modifies prior IRS guidance on how to make a partial termination determination. This new, temporary statutory provision looks solely at whether the number of active plan participants on March 31, 2021 is at least 80% of the number of active plan participants on March 13, 2020. Click here to read the full alert.
Author
