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N-2020-61: Special Funding and Benefit Limitation Rules for Single-Employer Defined Benefit Pension Plans under the CARES Act

Notice 2020-61 provides guidance regarding the special rules relating to single-employer defined benefit pension plans under § 3608 of the CARES Act.  Under these special rules, a contribution that would otherwise be required to be made to such a plan during 2020 is required to be made by January 1, 2021, and special interest adjustment rules apply to a contribution that is made after the otherwise applicable deadline.  In addition, an employer may elect to apply the benefit restrictions for underfunded plans under § 436 of the Code for the 2020 plan year (or a fiscal plan year that contains any part of 2020) using the plan’s funded status for the last plan year ending in 2019.

It will appear in IRB 2020-35 dated Aug. 24, 2020.