IRS Plan Includes Guidance on Student Loan Payments and Retirement Plans

The IRS has issued a new 2019-2020 Priority Guidance Plan, which sets forth guidance priorities for the Department of the Treasury and the IRS.

The 2019-2020 Priority Guidance Plan contains guidance projects that will be the focus of efforts during the 12-month period from July 1, 2019, through June 30, 2020 (the plan year). So, some items have already been completed. For example, the plan notes that final regulations have been issued regarding hardship withdrawals and regarding missing participants and uncashed checks.

The IRS says the published guidance process can be successful only if it has the benefit of the insight and experience of taxpayers and practitioners who must apply the internal revenue laws. It invites the public to continue to provide comments and suggestions as the agency develops guidance throughout the plan year.

Listed in the new Priority Guidance Plan are regulations updating life expectancy and distribution period tables for purposes of the required minimum distribution (RMD) rules. Current legislation being considered by the Senate would push RMDs to a later age.

The plan also includes guidance on student loan payments and qualified retirement plans and 403(b) plans. Student loan repayment programs have gained interest by employers as well as lawmakers. In August 2018, the IRS issued a Private Letter Ruling sanctioning a student loan repayment program tied to the 401(k) plan of employer Abbott.

The IRS is still working on regulations on the definition of governmental plan, regulations updating rules for service credit and vesting, and regulations on the treatment of future interest credits and annuity conversion factors under a hybrid defined benefit plan and adjustments under a variable annuity plan for purposes of satisfying certain qualification requirements, among other things.