Jorge Castro, Tom Cryan, Steven Dixon, Elizabeth Drake,* Anthony Provenzano,* and Lisandra Ortiz will present to the Tax Executives Institute's (TEI's) Denver Chapter on April 21, 2021.
- Represented an energy company in connection with an IRS technical advice proceeding involving a "greater of" pension formula that the IRS initially viewed as creating a backloading issue, but subsequently relented by issuing Rev. Rul. 2008-7.
- Obtained VCP approval for method of correction for ESOP operation issue for large energy company, avoiding millions of dollars in potential correction costs.
- Obtained a private letter ruling (PLR) applying net unrealized appreciation to participant directed investments for agricultural company (PLR 200509032).
- Assisted a government contractor, confronting the expiration of its primary contract, in developing various risk management and cost reduction strategies associated with certain plan terminations, benefit reductions, and layoffs likely to occur as a result of the contract expiration.
- Provide advice with respect to defined benefit plans of large and mid-size companies, including hybrid plans, with respect to application of Pension Protection Act provisions.