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Professor Nedley Series
"QDRO's"
Qualified Domestic Relations Orders
A Qualified Domestic Relations Order is a terribly misunderstood, yet simple legal document. Unheard of by the very people that are most affected by the order, feared by their lawyers because it somehow involves the Internal Revenue Code over which they have no control and confused by the companies and trusts that must deal with them, because their tax advisors drafted the language with which they must comply. This web page is for the sole purpose of helping everyone just "get along" and understand what it is that congress was trying to do back in 1984 when they passed the "Tax Simplification Act".
What is It?: A QDRO is a creature of the Internal Revenue Code and the Tax Simplification Act of 1984. The term QDRO stands a for Qualified Domestic Relations Order. A Domestic Relations Order (DRO) (The more correct term or acronym - DRO - never seemed to catch on like the term QDRO, the Professor knows not why) is simply a family law order made by a state court in a family law action. The order may cover property division, alimony, child support and includes payments made to a spouse, former spouse, child or other dependent of a plan participant In California any Superior Court judge or commissioner can make such an order in a pending divorce or separation case. The lesson in this paragraph is that just because you've settled the case or gotten an order out of the judge you still don't have an enforceable order.
What Kind of Private Plans Are Covered?: A QDRO applies to qualified plans including 401(k)'s, 403(b)'s, and 457's. A QDRO may be used to divide the entire contents of an IRA and in doing so the tax hit may be deferred by placing the money into another qualified IRA under the control of the Alternate Payee as opposed to the Plan Participant. (See Pub 575 Pensions and Annuities)
What it is Not: A DRO that has not been qualified is NOT a QDRO. A QDRO under the Internal Revenue Code applies only to private employer's plans, therefore by definition (with a unique exception*) QDRO's do not apply government plans such as PERS, STERS or JRS. They also are not applicable to military plans, so it is incorrect to say "I'll have my people draft a QDRO and we'll submit it to DFAS to get those military benefits paid to my client". The lesson in this paragraph is to limit the way that you toss around the term "QDRO', You'll sound a lot more knowledgeable if you simply refer to the order as "the order" or "the plan order". (* The University of California Retirement System (UCRS) refers to their plan orders as QDRO's, but the Internal Revenue Code Provisions do not apply)
Isn't the Judges Signature All That I Need?: No. The Judge's signature has simply created an order that so far lacks all of the power and perks (such as enforcement) given to a QDRO by the tax code. The lesson here is that Federal rules trump state judicial power. Heck, the judges spouse trumps judicial power.
When is it Qualified?: It is qualified when the designated representative of the employer or union's pension plan trust has reviewed the order (DRO) and says that it is qualified. Until then it is simply an order. A state court has no power to order that a plan be qualified. The Department of Labor believes that qualification orders must come from Federal Court. The lesson here is that there is probably a clerk somewhere that does all of the work and controls the whole shebang and you'd darn well be smart to treat him/her well and seek their assistance in completing the job and thank them nicely when your all done.
Why Does Anyone Care?: If my spouse agrees to pay me my share of the plan payments and he/she is trustworthy, why do I want to go to the expense of preparing a QDRO? All distributions from a qualified pension plan are taxable to the plan participant and without a QDRO even though the payments are made as scheduled they remain taxable in their entirety to the plan participant. This is not a good result for the participant or the participant's lawyer. This is tracked through the inevitable 1099P. Once "qualified" the tax burden may be shifted to the Alternate Payee An exception to burden shifting would be child support.
How to Draft a Qualifiable DRO:
Call the plan trustee and ask for their pro forma order and then use it.
The QDRO must relate to child support, spousal support or marital property rights.
The alternate payee must be a spouse, former spouse, child or other dependent of a plan participant.
Use those magical names - "Plan Participant" and "Alternate Payee". If you're the attorney and have a problem so far - use a different attorney's name.
What are the limits in payment provisions? IRC§414(p)
The order must not require a plan to provide an alternate payee or participant with any type or form of benefit, or any option, not otherwise provided under the plan
The order must not require a plan to provide for increased benefits (determined on the basis of actuarial value)
The order must not require a plan to pay benefits to an alternate payee (Ie W-2) that are required to be paid to another alternate payee (ie W-1)under another order previously determined to be a QDRO
The order must not require a plan to pay benefits to an alternate payee in the form of a qualified joint and survivor annuity for the lives of the alternate payee and his or her subsequent spouse
In other words, anything that actuarially increases the value of the plan.
What information must a domestic relations order contain to qualify as a QDRO under ERISA?
The name and last known mailing address of the participant and each alternate payee
The name of each plan to which the order applies
The dollar amount or percentage (or the method of determining the amount or percentage) of the benefit to be paid to the alternate payee
The number of payments or time period to which the order applies
Reference: ERISA § 206(d)(3)(C)(i)-(iv); IRC § 414(p)(2)(A)-(D)
Note: A QDRO does not have to be a separate judgment as is often thought by divorce practitioners. The proper provisions may well be contained in one all inclusive judgment. The problem you run into is local culture. ie What will local employers and unions accept with the least amount of fighting over the terms and conditions. Also local practice may dictate sending the job to local tax or pension practitioners and you or they may consider that the entire judgment is TMI (Too Much Information).
Note: You may make QDRO's payable to a guardian.
Note: One QDRO may apply to two or more plans with one or more employers as long as the plans are clearly identified and the terms are clear.
