Pension Protection Act Blog

June 30th marks the end of the IRS’ 2007-2008 Priority Guidance Plan. Tomorrow, making barely a ripple in the employee benefits universe, the IRS’ 2008-2009 Priority Guidance Plan will begin. Of course, the IRS has not released the 2008-2009 Priority Guidance Plan yet. They traditionally release Priority Guidance Plans during the month of August.

June 30th is also the mid-point in 2008 for calendar year plans, and is just a good day to reflect on what guidance the IRS has released so far this year, and what guidance is likely to be released before the Cycle D Cumulative List is released later this year. The IRS posts all guidance issued since January 1, 2008 on their website here.

Reviewing most of this guidance reveals that the IRS has really had a dual agenda this year. One part of the agenda has been issuing guidance for housekeeping issues, such as guidance needed in order to update cafeteria plans and non-qualified deferred compensation plans before the end of this year. The other part of the agenda has been issuing guidance to implement the Pension Protection Act.

With at least two bills pending before Congress to amend the Pension Protection Act - the Pension Protection Technical Corrections Act of 2008 and the Pension Protection Act ERISA Amendments of 2008 - one of the bills is likely to pass and create more PPA guidance items on the 2008-2009 Priority Guidance Plan.

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