EAM16 (3): No IRS Representation

In my last blog I mentioned that there is no Internal Revenue Service (IRS) representation at this year’s Enrolled Actuaries meeting but that does not mean that there are no speakers who happen to also be employees of the IRS.  For example, tomorrow there is Session 701 Dialogue with the IRS/Treasury described as:

A panel of high-ranking officials and experienced practitioners field your questions on a number of challenging issues. This is your chance to ask what you’ve always wanted to know about guidance. This session is not intended to address specific client issues.

with speakers:

  1. Kyle N. Brown U.S. Department of the Treasury
  2. Linda Marshall Internal Revenue Service
  3. Harlan M. Weller U.S. Department of the Treasury
  4. Carolyn E. Zimmerman Internal Revenue Service

However , anything said will be the views of the speakers, as they will make clear in the introduction, and not necessarily those of their employer whose views will still be up for speculation as Mr. Brown proved in a ‘Late Breaking Developments’ session he spoke at today where, according to my notes, he revealed:

The Employee Plans unit has put a lot of resources into and there has been an “incredible focus over the last year or so” on MEPRA (the law that allowed multiemployer plan benefits to be cut) so apparently other areas got less attention.

There happened to be an electrical fire last week at the IRS national headquarters so the building was closed most of last week.

There has been a reorganization of the agency between Operations and Chief Counsel where the latter is in charge of developing guidance (though actuaries from Operations do get to be on the team writing guidance if the material is math-centric).

No gray book since it took 300 man-hours to put together the answers.

No gray book since gray book answers were being used in court briefs and guidance development.

Future state: IRS is examining how they interact with taxpayers. “Wait and see.”

New mortality tables in 2017?

Finally, in response to the question about the requirement in proposed regulations that for each rate group in the general test the formula must apply to a reasonable classification of employee (classification by name not being reasonable) and, if not, the Average Benefit Test cannot be used and the plan must pass the Ratio Percentage Test which, according to one actuary, would “make 50% of their small plan business plans disqualified’ Mr. Brown could only say:

“We have heard.”

11 responses to this post.

  1. Posted by Anonymous on April 13, 2016 at 10:25 pm

    Actuary very interesting, especially if those IRS representatives speak on HOW and WHEN the Feds are going to fully fund their P&B. Yes including Armed Forces. No not by printing money.

    Reply

    • Posted by Tough Love on April 13, 2016 at 10:50 pm

      Trying to divert the discussion focus from the need to materially reduce the grossly excessive STATE and LOCAL Public Sector pensions ……. where even the bad idea of a printing-press-solution isn’t available ?

      Reply

      • Posted by Smooth Moderation Difficult on April 15, 2016 at 1:29 pm

        Actually, the subject of this article is the IRS. Not a diversion.

        The “need to materially reduce the grossly excessive STATE and LOCAL Public Sector pensions …….”

        Is …your… obsession.

        And delusion.

        Reply

        • Posted by Smooth Moderation Difficult on April 15, 2016 at 1:29 pm

          And diversion.

          Reply

          • Posted by Tough Love on April 15, 2016 at 1:48 pm

            Sorry, but this discussion is above your grade level …… as a light bulb changer.

          • Posted by Smooth Moderation Equal on April 15, 2016 at 7:42 pm

            “Why do people always assume that volume will succeed when logic won’t? – Damon” 

            (L.J. Smith, Nightfall)

            Volume …or CAPS LOCK, ad hominem nonsense, repetition, excess superlatives, diversion, etc.

            You are the diverter, and not for the first time.

          • Posted by Tough Love on April 15, 2016 at 9:13 pm

            And why do some people (Public Sector workers/retirees ….such as yourself) so insistent that THEY (yes, in CAPITALS) are deserving of so much more than identically situated Private Sector Taxpayers ?

            I will not be swayed.

          • Posted by Smooth Moderation Difficult on April 17, 2016 at 2:56 am

            And why do some people ( ….such as yourself) insist that public workers (…such as myself) are receiving more than identically situated Private Sector Taxpayers ? …With absolutely no idea what my pay and benefits are, and even less idea of what “identically situated” private sector workers receive. Other than what is conjured in your fevered imagination, of course.

          • Posted by Tough Love on April 17, 2016 at 9:34 am

            Quoting SMD …..

            “And why do some people ( ….such as yourself) insist that public workers (…such as myself) are receiving more than identically situated Private Sector Taxpayers ? …With absolutely no idea what my pay and benefits are”

            Why ?

            Because Public Sector salaries are irrelevant to the RATIO of Public-to-Private Sector pension calculations, BOTH pensions being functions of the richness of the “formula-factor”, the inclusion (or not) of COLA-increases, and the youngest age at which you can retire and begin collecting a pension WITHOUT an actuarial reduction for retiring at a young age.

            Educate yourself …. and lower lower your greed and enormous sense of entitlement.

          • Posted by S Moderation Douglas on April 21, 2016 at 11:05 pm

            “Public Sector salaries are irrelevant to the RATIO of Public-to-Private Sector pension calculations”

            But public sector salaries are relevant to total compensation.

            I will not be suede !!!

  2. Posted by Anonymous on April 14, 2016 at 8:50 am

    Fair and equal, right? No exceptions, wrong!

    Reply

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