Benefits alert: American Rescue Plan Act guidance by IRS for single employer DB plans emphasizes written elections for compliance

Internal Revenue Service (IRS) Notice 2021-48 has been released with compliance guidance under the American Rescue Plan Act of 2021 (ARPA) for single employer defined benefit (DB) pension plan sponsors and their U.S. tax-qualified retirement plan advisors. The Notice emphasizes that the permissible actions for meeting the cash contribution requirements for plan years in 2019, 2020, 2021, and 2022, which offer significant flexibility to adopt ARPA provisions, must be memorialized by plan sponsors’ written elections.