IRS Employee Plans Division (EP) Director Robert Choi on Feb. 23 issued a memo to EP determinations and examinations employees that sets forth interim guidelines they are to use in reviewing multiemployer collectively bargained plans that provide for a normal retirement age (NRA) earlier than 62, but not earlier than 55.
Under these guidelines EP determinations and examinations employees are to:
1. determine whether the plan is maintained pursuant to at least one collective bargaining agreement; and
2. determine whether the plan is a multiemployer plan.
If these conditions are satisfied, the NRA shall be considered to be reasonably representative of the typical retirement age for the industry in which the covered workforce is employed.
The memo became effective on Feb. 23, 2016 and states that this guidance will be incorporated into IRM 7.11.1 and 4.72.14.3 by Feb. 22, 2018.
Under these guidelines EP determinations and examinations employees are to:
1. determine whether the plan is maintained pursuant to at least one collective bargaining agreement; and
2. determine whether the plan is a multiemployer plan.
If these conditions are satisfied, the NRA shall be considered to be reasonably representative of the typical retirement age for the industry in which the covered workforce is employed.
The memo became effective on Feb. 23, 2016 and states that this guidance will be incorporated into IRM 7.11.1 and 4.72.14.3 by Feb. 22, 2018.
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