Nokia’s Application to the IRS for a Favorable Determination Regarding the Nokia Retirement Income Plan

Dear Brothers and Sisters:Active employees were sent an email last Friday regarding the above. First, this notice was not intended to go to the Active Represented population as it only pertains to the management employees. If you received the email you will see at the very bottom it states “Excluding (i) employees represented for purposes of collective bargaining by the Communications Workers of America, and (ii) employees who are not eligible for the NRIP’s Cash Account Program (CAP) but who are eligible to participate in another tax - qualified plan of No AC.”CWA T&T Office asked for clarification on the letter of determination. This is the response they received.” This is a routine filing. The company has regularly sought and obtained favorable determination letters (DLs) from the IRS for its tax - qualified plans in the past (until the IRS froze the DL program in 2016). In 2019, the IRS announced that it would once again begin accepting applications from employers but only with respect to “statutory hybrid plans” (sometimes called cash -balance plans). The Nokia Retirement Income Plan (the “NRIP”) is such a plan. While an employer is not required to apply for a DL, Nokia of America Corporation (NoAC) has decided to take advantage of this opportunity to seek an updated letter for the NRIP. As set forth in the company’s e-mail to employees, having such a letter provides assurance to the employer, employees, and others that the benefits earned under the plan are notcurrently taxable to employees but are “tax deferred” in accordance with the provisions of and as permitted under the tax code. For employers that are required to make funding contributions to a plan, the letter also provides assurance that the contributions are tax-deductible to the employer.  In addition, “NoAC does not currently have an opportunity to seek an updated letter for the Nokia Retirement Plan (the “NRP”). The last time the IRS issued a favorable determination letter for the NRP was July 1, 2014. That said, despite the discontinuance of the DL program for non-cash balance plans, the last-issued letter for the NRP is still considered valid and legally operative.”Also AT&T is also seeking the same determination for their Time Warner Plan.In Unity,R.K. FerdinandsenPresidentCWA Local7590