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U.S. Supreme Court Agrees to Hear Arguments Involving Federal Health Insurance Exchange Subsidies

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 Halbig v Burwell Health Insurance Health Insurance Exchanges IRS King v Burwell Popular SCOTUS Subsidies Tax Credits

DELAYED! HPID Deadline Is No Longer November 5

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

11/4/2014 - Healthcare Healthcare Reform HHS HPID

REMINDER: HPID Deadline is November 5th

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

10/31/2014 - Healthcare HHS HIPAA HPID Self-Insured Health Plans Third-Party

IRS and DOL Issue Favorable Guidance on Lifetime Income Provided Through Target Date Funds in Retirement Plans

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

10/29/2014 - Annuities Deferred Private Annuities Defined Contribution Plans DOL Investment Funds IRS Target Date Funds U.S. Treasury

Proposed Approach for Applying the “Look-Back” Method When the Section 4980H Measurement Period Changes

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

10/17/2014 - Affordable Care Act Employer Mandates Full-Time Employees IRS Look-Back Measurement Period Shared Responsibility Rule

Legal Alert: IRS Reaches a Split Decision on Rollover Allocation Rules

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

9/29/2014 - 403(b) Plans 457(b) Plans Distribution Rules IRS Qualified Retirement Plans

Legal Alert: Final Rules on Compensation Deduction Limit for Health Insurers

The Internal Revenue Service (IRS) and the Department of Treasury (Treasury) have issued final regulations under section 162(m)(6) of the Internal Revenue Code of 1986, as amended (Code), which limit the deduction certain...more

9/26/2014 - Compensation & Benefits Healthcare Independent Contractors IRS U.S. Treasury

Legal Alert: New PPACA-related “Family Status” Changes for Cafeteria Plans

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

9/26/2014 - Affordable Care Act Cafeteria Plans Employer Group Health Plans Employer Mandates Health Insurance Exchanges IRS Look-Back Measurement Period

Legal Alert: It’s Time to Review Benefit Denial Letters

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

9/9/2014 - Compliance Contract Drafting Denial of Benefits ERISA

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

Whose Risk Is It Anyway? New Revenue Ruling Provides Guidance for Employee Benefits Captives

On May 8, the IRS issued Rev. Rul. 2014-15, 2014-22 I.R.B. 1, which provides guidance in the rapidly expanding area of insuring or reinsuring employee benefits with captives. ...more

5/16/2014 - Affordable Care Act Captive Insurance Company Employee Benefits ERISA IRS Reinsurance

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

The Honeymoon Is Over: IRS Says It Is Time to Amend Plans to Cover Same-Sex Spouses

On April 4, 2014, the Internal Revenue Service (IRS) released Notice 2014-19, which provides a series of Q&As regarding the application of the U.S. Supreme Court’s decision in United States v. Windsor and the IRS’s prior...more

4/8/2014 - IRS Marriage Same-Sex Marriage SCOTUS Tax Benefits US v Windsor

Legal Alert: DOL Proposes 408(b)(2) Disclosure Guide

On March 12, 2014, the Department of Labor (DOL) published in the Federal Register a proposed amendment to its disclosure requirements for “covered service providers” to retirement plans under ERISA § 408(b)(2) that would...more

3/13/2014 - Disclosure Requirements DOL Employee Benefits ERISA Retirement Plan

Roll Over, Bobrow: Surprising Tax Court Decision on IRA Rollover Rules

On January 28, 2014, the U.S. Tax Court held in Bobrow v. Commissioner that the rule limiting IRA rollovers to one per 12-month period in Internal Revenue Code Section 408(d)(3)(B) applies across all of a taxpayer’s IRAs,...more

2/19/2014 - IRA IRA Rollovers

Proposed Regulation Incorporates IRS Litigation Position on UBTI for VEBAs and SUB Trusts

On February 6, 2014, the Internal Revenue Service (IRS) proposed new regulations for calculating the unrelated business taxable income (UBTI) of IRC section 501(c)(9) voluntary employees’ beneficiary associations (VEBA) and...more

2/14/2014 - Business Taxes Corporate Taxes IRS Trusts UBTI

Insurance Topics We Will Be Watching in 2014

With the first month of the year behind us, this report outlines major insurance topics that we will be watching throughout 2014. Forces, trends and events that we believe will affect regulation, transactions and...more

2/7/2014 - Affordable Care Act Casualty Insurance Federal Insurance Office Healthcare Healthcare Reform Insurance Reform Insurers NAIC Property Insurance Reinsurance

2013 in Review: ERISA Individual Prohibited Transaction Exemptions and Advisory Opinions

In 2013, the Department of Labor (DOL) maintained a modest program of advance guidance under the Employment Retirement Income Security Act of 1974, as amended (ERISA), in response to requests from the regulated community....more

1/7/2014 - DOL ERISA Prohibited Transactions

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