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IRS Finalizes Guidance on Rev. Rul. 81-100 Group Trusts, and Insurance Company Separate Accounts

In Rev. Rul. 2014-24, scheduled for publication on September 8, 2014, the Internal Revenue Service (the Service) substantially completed its pending guidance on Rev. Rul. 81-100 group trusts by permanently authorizing the...more

8/27/2014 - ERISA Final Guidance IRC IRS Puerto Rico Retirement Plan

DOL Requests Information on Brokerage Windows in Defined Contribution Plans

On August 20, 2014, the U.S. Department of Labor (DOL) released a request for information (RFI) about the use of brokerage windows, self-directed brokerage accounts, and similar arrangements in participant-directed defined...more

8/22/2014

Financial Service Company’s Nonqualified Plan Found to be an ERISA Pension Plan

In Tolbert v. RBC Capital Markets (July 14, 2014), the U.S. Court of Appeals for the Fifth Circuit held that a deferred incentive compensation plan maintained by a financial services company for certain employees was an...more

8/7/2014 - Employee Benefits ERISA Pensions Qualified Benefit Plans

Circuit Court Split Casts Doubt on PPACA Subsidies for Individuals and Employer Penalties in 36 States

Two federal appeals courts issued conflicting rulings on July 22 on whether individual premium subsidies under the Patient Protection and Affordable Care Act (PPACA) are available in 36 states that have federally run...more

7/25/2014 - Affordable Care Act Employer Mandates Health Insurance Exchanges Healthcare Healthcare Reform Subsidies Tax Credits

RMD Rules for Longevity Annuities Finalized

Longevity annuities are contracts that provide life annuity payments typically commencing at age 80 or 85; in many (but not all) cases, that is the only benefit the contract provides. As such, these contracts may offer...more

7/3/2014 - Annuities Estate Planning Required Minimum Distributions Retirement Plan

Inherited IRAs Are Not Bankruptcy-Exempt as “Retirement Funds”

On June 12, 2014, the U.S. Supreme Court unanimously held in Clark v. Rameker that an inherited individual retirement account (IRA) does not qualify for the “retirement funds” exemption in the Bankruptcy Code and is not...more

6/17/2014

IRS Releases Additional Rulings on Lump-Sum Windows

The practice of offering lump-sum distributions has become increasingly popular among defined benefit plan sponsors looking to decrease volatility or other defined benefit plan risks. In some situations, plan sponsors offer...more

6/13/2014 - Benefit Plan Sponsors Defined Benefit Plans ERISA IRC IRS Lump Sum Offers Private Letter Rulings Title I Vesting

IRS Issues Retroactive Relief Requirement for Delinquent Retirement Plan Form 5500

Until now, those who used the Department of Labor’s Delinquent Filer Voluntary Compliance Program (DFVCP) to obtain relief from penalties for failing to timely file Form 5500 automatically qualified for relief from the...more

5/29/2014 - Compliance IRS Retirement Retirement Plan Voluntary Disclosure

IRS Offers Two New Due Diligence Safe Harbor Procedures for Accepting Rollovers into Qualified Plans

On April 3, 2014, the Internal Revenue Service released Revenue Ruling 2014-9 (the Ruling), which provides guidance helpful to the administration of rollovers by tax-qualified retirement plans by...more

4/9/2014 - Due Diligence IRA Rollovers IRS Qualified Retirement Plans Retirement Plan Safe Harbors

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