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R. Randall Tracht

R. Randall Tracht

Morgan Lewis


Latest Publications

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New Opinion and Advisory Program for Pre-Approved 403(b) Plans

The IRS releases new procedures and sample plan language to assist 403(b) plan sponsors in obtaining pre-approval of 403(b) plan documents and to ensure documentary compliance with 403(b) requirements....more

4/18/2013 - 403(b) Plans Advisory Opinions IRS Pre-approval Required Documentation

PBGC Proposes New Regulations Under Reportable Events Rule

New rules signal relief for financially sound plans and plan sponsors and are consistent with PBGC's section 4062(e) enforcement policy for "plant shutdown" liability....more

4/12/2013 - Benefit Plan Sponsors Enforcement Actions ERISA PBGC Proposed Regulation Reporting Requirements Safe Harbors

Expanded Guidance from IRS on 403(b) Plans

IRS amends EPCRS, significantly affecting 403(b) plans, and issues guidance to assist 403(b) plan sponsors in identifying and correcting defects....more

4/2/2013 - 403(b) Plans Compliance EPCRS IRS Retirement Plan

Fiscal Cliff Legislation Expands In-Plan Roth Conversion Opportunities

American Taxpayer Relief Act extends the existing, limited in-plan Roth conversion option to all amounts under plans that allow elective deferrals, including those amounts not yet eligible for distribution. The American...more

1/31/2013 - 401k American Taxpayer Relief Act Benefit Plan Sponsors Fiscal Cliff Roth Conversions

IRS Updates and Expands Qualification Correction Program

New provisions for correcting operational and plan document errors take effect on April 1. On December 31, 2012, the Internal Revenue Service (IRS) updated its Employee Plans Compliance Resolution System (EPCRS) through...more

1/31/2013 - Benefit Plan Sponsors EPCRS ERISA IRS Retirement Plan Voluntary Correction Program

PBGC Changes Enforcement Policy Under ERISA Section 4062(e)

No action will be taken against creditworthy companies or small pension plans; no financial guarantees will be required for approximately 92% of applicable employer-plan sponsors. On November 2, the Pension Benefit...more

11/13/2012 - PBGC

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