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Notice 2018-81: Church plans, notifying IRS about treatment as single employer

Church plans, notifying IRS about single employer

Notice 2018-81—which will appear in the Internal Revenue Bulletin 2018-43 (October 22, 2018)—provides guidance as to how taxpayers are to notify the IRS of the revocation of an election to aggregate or disaggregate certain church-related organizations from treatment as a single employer.


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Under measures enacted in 2015, an election can be made to aggregate or disaggregate church-related organizations for purposes of being treated as a single employer under section 414(c). The election, once made, applies to all subsequent plan years unless revoked. The legislation, however, did not set out specific rules as to how to make or revoke this election other than the IRS is to be notified of the revocation of the election. 

Notice 2018-81 sets out how to provide the IRS with notice of revocation of an election. The notice is effective for revocations of elections made on or after October 22, 2018. The IRS also has requested comments as to whether additional guidance is needed. Comments are due by December 21, 2018.

Read Notice 2018-81 that appears on page 666 of IRB 2018-43 [PDF 373 KB]

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