Employee Benefit Plan Developments—2020 Year in Review | Perkins Coie
, Q&A-15 (rev. September 19, 2020). The IRS stated that employees who were rehired by the end of the review period would not generally be considered to have experienced an employer-initiated severance when evaluating a partial plan termination. If there is a partial plan termination, affected participants (those who experienced an employer-initiated severance) must be 100% vested. E-signatures and Remote Notary Guidance from IRS (Retirement) In response to the COVID-19 pandemic, the IRS iss...
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