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Individual Comments on Suspension of Pension Benefits Regs

MAR. 10, 2016

Individual Comments on Suspension of Pension Benefits Regs

DATED MAR. 10, 2016
DOCUMENT ATTRIBUTES
  • Authors
    Carlson, Harry
  • Cross-Reference
    REG-101701-16 2016 TNT 27-11: IRS Proposed Regulations.
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2016-5668
  • Tax Analysts Electronic Citation
    2016 TNT 52-26
[Editor's Note: The IRS received many letters that are substantially similar to the one appearing at this citation.]

 

PUBLIC SUBMISSION

 

 

Docket: IRS-2016-0005

 

Additional Limitation on Suspension of Benefits Applicable to Certain

 

Pension Plans Under the Multiemployer Pension Reform Act of 2014

 

(REG-101701-16)

 

 

Comment On: IRS-2016-0005-0001

 

Additional Limitation on Suspension of Benefits Applicable to Certain

 

Pension Plans under the Multiemployer Pension Reform Act

 

 

Document: IRS-2016-0005-0029

 

Additional Limitation on Suspension of Benefits Applicable to Certain

 

Pension Plans Under the Multiemployer Pension Reform Act of 2014

 

(REG-101701-16)

 

Submitter Information

 

 

Name: Harry Carlson

 

Address:

 

6808 E Shadow Lake Drive

 

Lino Lakes, MN, 55014

 

Email: hndcarlson@aol.com

 

General Comment

 

 

The Kline-Miller Multiemployer Pension Reform Act has proven to be cruel and very unfair.

See Attachment

 

* * * * *

 

 

Attachments

 

 

The Kline-Miller 3-10-16

The Kline-Miller Multiemployer Pension Reform Act has proven to be cruel and very unfair. It has picked winners and losers among participants, who through their earnings, paid equally into the Central States Pension Fund (CSPF). This makes it very difficult to comment.

My comment is in regard to whether the words "to the maximum extent permissible" should be added to subclause II in the final regulations. These five words make a major change in the law as it is written and interpreted. For those reasons I support the proposal by The Treasury Department and the IRS to not add these words to benefits described in subclause II.

At town hall meetings and on many conference calls we have heard that Treasury has to follow the law. To add "to the maximum extent permissible" to subclause II would be writing new law.

The Department of Labor was given oversight authority in choosing independent fund managers and changing investment strategies for CSPF over the past thirty plus years. The Department of Labor seemingly sat silent while the fund failed.

Representatives Kline and Miller attached as a rider to the must pass omnibus spending bill legislation written by the National Coordinating Committee for Multiemployer Plans (NCCMP) cutting the very pensions that the Department of Labor was to oversee. These cuts are not equitable as they range from zero to as much as seventy percent.

The government backstop to cover failed pension funds, the Pension Benefit Guaranty Corporation, is also projected to become insolvent; one reason being that Congress failed to require adequate insurance premiums for multiemployer pensions.

Now, after all these failures, in which participants had no say or choice, we are placed in the hands of two more government agencies, the IRS and the Department of Treasury. If this was not so life shattering it would be comical.

Thank you.

DOCUMENT ATTRIBUTES
  • Authors
    Carlson, Harry
  • Cross-Reference
    REG-101701-16 2016 TNT 27-11: IRS Proposed Regulations.
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2016-5668
  • Tax Analysts Electronic Citation
    2016 TNT 52-26
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