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NOTES 835 Tax Lawyer, Vol. 54, No. 4 NOTE GIVING TEETH TO THE PROHIBITIONS OF ERISA: FORBIDDEN ACTUARIAL CALCULATIONS IN CASH BALANCE PLANS AS PER ESDEN V. BANK OF BOSTON In Esden v. Bank of Boston,1 the Second Circuit held that the defendant bank violated the provisions of the Employee Retirement Income Security Act (ERISA) when it, for the purpose of making a lump-sum distribution out of a cash balance plan, actuarialized the present equivalent value of the participant’s account using an...