Proposed Regulations on Normal Retirement Age

By Tony Roda

In January 2016, the U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations on the applicability of the 2007 normal retirement age (NRA) regulations to state and local governmental pension plans, i.e., public pension plans that meet the definition of Internal Revenue Code section 414(d). While final regulations on NRA were promulgated in 2007, the applicability of those rules to state and local government pension plans was delayed by a series of Treasury-IRS guidance. The article discusses the unique issues involved in applying the rules to state and local pension plans and explains the structure proposed 2016 regulation, including the safe harbor regime.


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