On Friday, the U.S. Supreme Court announced that it would review the U.S. Court of Appeals for the Fourth Circuit’s decision in King v. Burwell. In that case, the Fourth Circuit held that tax credits for health insurance...more
11/12/2014
/ Affordable Care Act ,
Employer Mandates ,
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Health Insurance ,
Health Insurance Exchanges ,
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King v Burwell ,
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Subsidies ,
Tax Credits
This past weekend the U.S. Department of Health and Human Services (HHS) indefinitely delayed enforcement of the requirement that all self-insured health plans obtain a Health Plan Identifier number (HPID). ...more
The U.S. Department of Health and Human Services (HHS) is requiring all self-insured health plans to obtain a Health Plan Identifier number (HPID) as part of its compliance efforts under the Health Insurance Portability and...more
On October 23 and 24, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued coordinated guidance on lifetime income provided through target date funds held by retirement plans. According to an...more
The Internal Revenue Service (IRS) recently issued Notice 2014-49 which describes a proposed approach for determining an employee’s full-time or part-time status for purposes of the employer shared responsibility rules under...more
On September 18, the Internal Revenue Service (IRS) issued Notice 2014-54, which clarifies that, subject to some limitations, a single distribution of pre-tax and after-tax amounts from a qualified retirement plan, a 403(b)...more
The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more
On August 7, the U.S. Court of Appeals for the Sixth Circuit decided in Moyer that the contractual time limits governing the period during which a participant must initiate judicial review of a benefits denial must be...more
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
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
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
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
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
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
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
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
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