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IRS Provides Preview of Anti-Cutback Regs on Early Retirement and Retirement-Type Subsidies
Internal Revenue Service [IRS] 
[Official Guidance] Jan. 13, 2003
Excerpt: Questions have arisen as to whether a benefit that is contingent on the occurrence of an unpredictable event, such as a plant shutdown or an involuntary separation, is a retirement-type subsidy and, thus, protected by 411(d)(6). Since the enactment of REA, three circuit courts have held that an unpredictable contingent event benefit is protected, while one has held that it is not.
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