In Notice 2020-42, the IRS has temporarily permitted electronic notarization or witnessing on forms relating to certain elections for qualified retirement plans. State law requirements must be satisfied for a remote notarization. In Florida, we have electronic notarization available as of January 1, 2020. The IRS notice permits signatures "1) witnessed by a notary public in a state that permits remote notarization, or (2) witnessed by a plan representative using certain safeguards." 26 CFR § 1.401(a)-21 requires that the plan representative or notary be physically present. For such documents signed between January 1, 2020 and December 31, 2020, the physical presence requirement can be satisfied through remote witnessing or notarization. Hopefully, by the end of the year, our current health concerns will be a thing of the past.
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