News & Analysis as of

Benefit Plan Sponsors Employee Contributions

Patterson Belknap Webb & Tyler LLP

Interim Guidance on Matching Qualified Student Loan Payments

Until recently, employer matching contributions under qualified plans were required to be conditioned solely upon employee contributions made to the plan. However, one of the many changes enacted by the Consolidated...more

Bricker Graydon LLP

Too Little, Too Late? Plan Contribution Timing Requirements and How to Correct Delays

Bricker Graydon LLP on

One of the most basic duties of a defined contribution plan sponsor is to ensure that that there is no delay and participants’ salary deferral elections are correctly and timely deposited into the retirement plan. Not only is...more

Faegre Drinker Biddle & Reath LLP

Roth Employer Contributions

On December 20, 2023, the IRS issued Notice 2024-2, which provides question-and-answer guidance on various aspects of the SECURE 2.0 Act. This post focuses on the ability to make employer contributions (match or nonelective)...more

Holland & Knight LLP

IRS Issues Notice 2024-2 Outlining Guidance on SECURE 2.0 Provisions

Holland & Knight LLP on

The IRS issued Notice 2024-2 (Notice), which provides guidance in a question and answer format concerning certain provisions of the SECURE 2.0 Act of 2022 (SECURE 2.0). The following is a brief overview of key provisions in...more

Bricker Graydon LLP

The Gift That Keeps on Giving: New IRS Guidance on Roth Employer Contributions

Bricker Graydon LLP on

The Internal Revenue Service (IRS) gave plan sponsors an early Christmas gift with the release of new guidance late last year addressing several key provisions contained in SECURE 2.0. A welcome portion of the notice was...more

Bricker Graydon LLP

403(b) Plans - Not Your Average Salary Deferral Plan

Bricker Graydon LLP on

Congress continues to pass laws that move 403(b) plans ever closer to 401(k) plans, but 403(b) plans remain distinct. Understanding these differences allows you to maintain a compliant plan that best serves the needs of your...more

Davis Wright Tremaine LLP

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

Seyfarth Shaw LLP

Want to Put More Away in Your 401(k)? Qualified Plan Limits Generally Increase in 2024

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS just announced the 2024 annual limits that will apply to tax-qualified retirement plans. For a third year in a row, the IRS increased the annual limits, allowing participants to save even more in...more

Foley & Lardner LLP

Diving Into SECURE 2.0: New DOL Lost and Found, Updates to EPCRS, and Delayed Implementation of Roth Catch-up Requirement

Foley & Lardner LLP on

The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more

Allen Barron, Inc.

IRS Modifies and Clarifies Roth IRA Plan Catch-Up Payment Requirements

Allen Barron, Inc. on

A recent announcement from the IRS (IR-2023-62) modifies and clarifies Roth IRA catch-up payment requirements for contributors who are aged 50 or older.  IR-2023-62 delayed mandatory Roth IRA catch-up payments for high income...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Catching Up With the Times - IRS Issues Guidance Delaying Required Roth Catch-up Contributions

To the relief of plan sponsors everywhere, the Internal Revenue Service (IRS) recently issued Notice 2023-62, which provides guidance on the requirements of Section 603 of the SECURE Act 2.0 of 2022 relating to catch-up...more

Williams Mullen

Treasury Issues Anticipated Relief for New Catch-up Contribution Rule

Williams Mullen on

The Internal Revenue Service (“IRS”) provided welcome relief for administrators of plans offering catch-up contributions. Notice 2023-62, issued on August 25, essentially delays the effective date of a provision under the...more

McAfee & Taft

IRS guidance provides breathing room for implementing SECURE 2.0 Act catch-up contribution rule

McAfee & Taft on

As you probably already know, qualified retirement plans are permitted, but are not required, to allow participants who are age 50 or older to make additional elective deferrals (including designated Roth contributions),...more

Eversheds Sutherland (US) LLP

More time to catch up: IRS announces two year delay of Roth catch-up requirement

The IRS has announced a two-year “administrative transition period” for plan sponsors to implement the SECURE 2.0 Act provision requiring higher-income employees to make retirement plan catch-up contributions as Roth...more

Miller Canfield

IRS Delays Roth Catch-Up Requirement for High Earners

Miller Canfield on

On August 25, 2023, the IRS issued Notice 2023-62 to address certain industry concerns over implementation of Section 603 of the SECURE 2.0 Act. Section 603 relevantly provides that, beginning in 2024, participants eligible...more

Smith Gambrell Russell

IRS Issues Desired Relief for Plan Sponsors Trying to Comply with SECURE 2.0 Roth Catch-Up Requirement

Smith Gambrell Russell on

On Friday, the Internal Revenue Service (“IRS”) released Notice 2023-62 (the “Notice”) providing welcome relief to plan sponsors with respect to the new SECURE 2.0 requirement that all catch-up contributions made by...more

Venable LLP

SECURE 2.0 Roth Catch-up Requirement Delayed until January 1, 2026

Venable LLP on

On August 25, 2023, the IRS issued guidance delaying until January 1, 2026 the SECURE 2.0 requirement that any age 50 catch-up contributions by an employee with prior-year compensation over $145,000 be made on a Roth basis,...more

Foley & Lardner LLP

Diving into SECURE 2.0: More Changes That Will Help Make 401(k) Plan Administration Simpler and Other Possible Changes of Which to...

Foley & Lardner LLP on

The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more

Houston Harbaugh, P.C.

Sponsors of 401(k) Plans Without Roth Provisions May Want to Add Them Before 2024

Houston Harbaugh, P.C. on

Our prior bulletin summarized the multitude of changes applicable to 401(k) and other retirement plans under the recently enacted “SECURE 2.0” law. This bulletin focuses on one of those changes and a potential reason for...more

Faegre Drinker Biddle & Reath LLP

The SECURE Act 2.0: The Most Impactful Provisions #9 — Roth Treatment for Catch-up Contributions for Higher Compensated

The President signed the Consolidated Appropriations Act, which included SECURE Act 2.0, on December 29, 2022. SECURE Act 2.0 has over 90 provisions, some major and some minor; some mandatory and some optional; some...more

Warner Norcross + Judd

[Webinar] Employee Benefits SECURE Act 2.0 Series - Part 2: Distribution Rule Revisions - April 12th, 12:00 pm - 1:00 pm ET

Warner Norcross + Judd on

Warner’s Employee Benefits Practice Group is pleased to present a webinar series on significant new retirement plan legislation, the SECURE Act 2.0. While we expect implementing the new law to take several years, some...more

Warner Norcross + Judd

[Webinar] Employee Benefits SECURE Act 2.0 Series - Part 1: Changes to Retirement Plan Eligibility and Contributions - March 28th,...

Warner Norcross + Judd on

Warner’s Employee Benefits Practice Group is pleased to present a webinar series on significant new retirement plan legislation, the SECURE Act 2.0. While we expect implementing the new law to take several years, some...more

Verrill

Pension-Linked Emergency Savings Accounts: Something Old, Something New, Something Borrowed, Something Forthcoming

Verrill on

Following the initial flurry of publications summarizing the retirement plan enhancements under the SECURE 2.0 Act of 2022 (“SECURE 2.0”), this post takes a deeper dive into one of those enhancements: the optional...more

Epstein Becker & Green

SECURE Act 2.0: What 401(k) Plan Sponsors Need to Know

Epstein Becker & Green on

On December 29, 2022, President Biden signed into law, as part of the Consolidated Appropriations Act of 2023, the SECURE 2.0 Act of 2022 (“SECURE Act 2.0”). SECURE Act 2.0 builds on 2019’s Setting Every Community Up for...more

Smith Gambrell Russell

SECURE 2.0 – What Retirement Plan Sponsors Need to Know Now

Smith Gambrell Russell on

In the final days of 2022, after months of back and forth, Congress adopted a myriad of law changes for qualified retirement plans, collectively known as the SECURE 2.0 Act of 2022 (“SECURE 2.0”). SECURE 2.0 builds on the...more

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