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New IRS Guidance on Long-Term, Part-Time Employee Retirement Plan Participation

New proposed regulations clarify how employers should implement retirement plan eligibility rules for long-term, part-time ("LTPT") employees. While some questions remain, the proposed regulations provide a number of welcome...more

IRS Uses Few Words to Implement Proposed Payroll Tax Deferral, but Leaves Many Questions Unanswered

Background - The Internal Revenue Code (the "Code") provides the Secretary of the Treasury with the authority to delay tax deadlines in times of national emergency....more

FFCRA Leave Documentation: What Is Required and What Is Recommended?

As we have discussed in prior advisories, employers are entitled to a tax credit to cover 100 percent of the expense of providing paid leave under the Families First Coronavirus Response Act (FFCRA). Both the FFCRA...more

IRS Promises Quick Recovery of Tax Credit for Families First Coronavirus Response Act Leave

As part of the Families First Coronavirus Response Act (FFCRA), signed by President Trump on March 18, 2020, certain employers (based on workforce size) must provide expanded paid sick leave and paid family leave to employees...more

Calculated to Be Understood by the Average Plan Participant – How Does the DOL Score?

ERISA requires Summary Plan Descriptions and other disclosures to be "written in a manner calculated to be understood by the average plan participant." ERISA section 102(a). ...more

Anticipated Proposed Regulations Clarify Hardship Distribution Rules

On November 9, 2018 the IRS issued proposed regulations that clarify changes made by the Bipartisan Budget Act of 2018, which generally expanded the ability of participants in 401(k) and 403(b) plans to obtain a hardship...more

Long-Awaited 457 Plan Regulations Provide Planning Opportunities for Tax-Exempt and Governmental Employers

On June 22, 2016, the Internal Revenue Service (IRS) and Treasury Department issued proposed regulations under Section 457 of the Internal Revenue Code, fulfilling a nearly decade-old commitment to provide additional...more

Section 409A: IRS Issues Proposed Regulations to Address Open Questions

On June 22, 2016, the Internal Revenue Service and Treasury Department issued proposed regulations under Section 409A of the Internal Revenue Code (409A Proposed Regs). The government noted that the 409A Proposed Regs are...more

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