Both CUNA and NAFCU have offered feedback to the IRS on clarification in determining the definition of “governmental plan” as it relates to nonqualified deferred compensation plans at federal credit unions.

At issue is IRS efforts to establish rules that would provide general guidance relating to the determination of whether a retirement plan is a governmental plan within the meaning of section 414(d) of the Internal Revenue Code. There are currently are no regulations interpreting this section of the tax code.  

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