The Employee Benefits Group provides updates and guidance for clients with retirement plans. First, the Department of Labor recently issued interim final regulations requiring new information to be included on ERISA-covered...more
While the 4 Questions during the Passover holiday asks why this night is different than all other nights, the Internal Revenue Service (IRS) has reminded us that this year for required minimum distributions (RMDs) are...more
Payroll Tax Relief Under CARES Act, FFCRA, and Executive Order - While the Coronavirus Aid, Relief, and Economic Security (CARES) Act permitted employers to defer depositing the portion of the FICA taxes the employer pays...more
As highlighted in our recent Tax Alert, in Notice 2020-51 (the Notice) the Internal Revenue Service (IRS) provides an extension of the 60-day rollover period to August 31, 2020 for individuals who have already taken a...more
The Department of Labor (DOL) made it easier to consolidate small retirement account balances with a prior employer into a new employer’s plan, now without the direct involvement of the participant....more
In Rev. Rul. 2019-19, which was issued on August 14, the Internal Revenue Service (IRS) took another small step in its undertaking to address tax issues raised by missing or unresponsive retirement plan participants. The...more
The Tax Cuts and Jobs Act of 2017 (“2017 Tax Act”) includes a provision that changed the rollover rules for certain plan loan offset distributions and that may not be well known to retirement plan sponsors and participants. ...more
This Client Advisory highlights important developments in the law governing employee benefit plans and executive compensation over the past year. It offers insight into what these developments mean for employers and plan...more
As the end of the calendar year approaches, sponsors of qualified retirement plans should consider whether their plan documents require updates to comply with important legal changes and deadlines. Below is a summary of some...more
The IRS recently updated its two model safe harbor explanations that can be used to satisfy the requirement under Section 402(f) to provide notices setting forth certain information to participants who are eligible for...more
The IRS has issued new model notices for recipients of rollover distributions from qualified retirement plans. The updated notices reflect changes from the 2017 tax reform act, as wells as regulatory changes enacted since...more
• The recent Tax Cuts and Jobs Act of 2017 (the Act), enacted on Dec. 22, 2017, contains a few rules that will impact benefit administrators. • This client alert focuses on changes made to the tax treatment of plan loan...more
In February of 2015, the Department of Treasury issued a reported entitled “General Explanation of the Administration’s Fiscal Year 2016 Revenue Proposals” (the “General Explanation”). The General Explanation is several...more
The Internal Revenue Service (IRS) has issued Revenue Procedure 2016-47, which provides for a new self-certification procedure for participants who receive retirement plan distributions but inadvertently miss the 60-day time...more
Final Roth Rollover Rules Retain Simplification of Prior Notice and Ease Rollovers for Participants with Both Roth and Pre-Tax Amounts in their 401(k) Plan Account - Prior to the proposed rules on Roth 401(k)...more
I blogged in the past about decisions in which taxpayers have used assets in their IRA to finance a new business. This structure is sometimes known as a ROBS or rollover for business startups. In 2013, the tax court held that...more
In furtherance of Section 902 of the American Taxpayer Relief Act of 2012 (ATRA), the Internal Revenue Service (IRS) recently issued Notice 2013-74 updating prior IRS guidance regarding so-called “in-plan” Roth conversions...more
Guidance confirms that plan sponsors have flexibility in designing and implementing a feature that allows participants to convert vested pre-tax balances to after-tax Roth balances....more
On December 11, 2013, the IRS issued IRS Notice 2013-74 which provides guidance on in-plan Roth rollovers. An in-plan Roth rollover is a rollover within a Section 401(k), Section 403(b) or governmental Section 457(b) plan to...more
The Internal Revenue Service has issued long-awaited guidance regarding the ability for participants in section 401(k), 403(b), and governmental 457(b) plans to convert balances from pre-tax and after-tax sources into Roth...more