When President George W. Bush signed the Pension Protection Act of 2006 (PPA) on Aug. 17, 2006, he added another chapter to a long saga regarding cash balance pension plans. Although the PPA provided clarity and certainty regarding the legality of cash balance plans, it also raised many questions regarding how the new rules would be applied. Since the PPA was enacted, the Treasury Department and the Internal Revenue Service have issued three sets of regulations, most recently issuing final and proposed regulations on Sept. 19, 2014.

This report looks at how the IRS and Treasury have interpreted the PPA provisions to date, and provides an overview of remaining open issues, as well as some highlights of how case law in this area has evolved.


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