Retirement Plan Employee Benefits Internal Revenue Service

News & Analysis as of

Recent Changes to the IRS Determination Letter Program

Effective January 1, 2017, except for the last batch of Cycle A filers who were permitted to submit determination letters by January 31, 2017 (i.e., filers with an EIN ending in 1 or 6), the IRS will no longer accept...more

Dealing with New IRS Qualification Requirements for Pension, Profit Sharing and 401(k) Plans, Effective January 1, 2017

The procedures for qualification of an employer sponsored individually designed pension, profit sharing or 401(k) plan for favorable tax deferred treatment under the Internal Revenue Code (“Code”) changed significantly...more

IRS Announces the Last Day of the Remedial Amendment Period for 403(b) Plans

The Internal Revenue Service recently issued Revenue Procedure 2017-18, which provides that the last day of the remedial amendment period for Code Section 403(b) retirement plans will be March 31, 2020. As discussed below,...more

IRS Announces the Last Day of the Remedial Amendment Period for 403(b) Plans

The Internal Revenue Service recently issued Revenue Procedure 2017-18, which provides that the last day of the remedial amendment period for Code Section 403(b) retirement plans will be March 31, 2020. As discussed below,...more

Remedial Amendment Period for 403(b) Plans

In Revenue Procedure 2017-8, the IRS announced that the remedial amendment period (“RAP”) for 403(b) plans would end on March 31, 2020. A RAP is a period in which a plan can be amended retroactively to comply with the...more

IRS Issues First Required Amendments List for Qualified Plans

In a previous blog, we discussed the IRS’ elimination of its five year staggered determination letter cycle for individually designed plans. The IRS recently provided guidance to help sponsors of individually designed plans...more

Newly Proposed IRS Rules Permit the Use of Forfeitures for QNECs and QMACs

On January 18, 2017, the IRS issued proposed regulations that expand the permitted uses of forfeitures in a 401(k) plan. Under the proposed rules, the definitions of “qualified nonelective contributions” (QNECs) and...more

IRS Relaxes Rules on Use of Forfeitures to Fund Safe Harbor Contributions and QNECs to 401(k) Plans

The IRS recently issued welcome guidance for sponsors of 401(k) plans. On January 18th, the IRS issued proposed regulations that permit forfeitures to be used to fund the employer’s safe harbor contributions, qualified...more

Are Individually Designed Retirement Plans Destined to Become Dinosaurs?

The Impact of Changes to the IRS Determination Letter Program - This January 2017 will see the last regular IRS determination letter applications filed for individually designed retirement plans. After this final Cycle A...more

Employment Law 2016 Review

Preparing for Medical Marijuana in Pennsylvania - Marijuana legalization reached Pennsylvania in 2016, bringing with it a host of new questions employers are going to have to answer. Signed into law on April 17, the...more

Puerto Rico Treasury Announces 2017 Limits on Qualified Retirement Plans

On December 8, 2016, the Puerto Rico Department of the Treasury issued its Tax Policy Circular Letter No. 16-07 (“CL 16-07”), announcing the applicable limits for 2017 for qualified retirement plans. Pursuant to Section...more

Ballard Opinion Letter Program to Replace IRS Determination Letter Program

The Internal Revenue Service has largely ended its determination letter program by which sponsors of individually designed retirement plans can obtain confirmation that their plan documents are tax-qualified. The IRS has...more

Holiday Horror Series: Part 2- Hectic Holiday Rollovers

With the holidays upon us, we all can relate to how easy it is to mistakenly overlook important things amidst the cheery holiday hustle and bustle: leaving the Christmas ham in the oven a few hours too long, forgetting to...more

The ERISA Litigation Newsletter - November 2016

This month we review a recent Second Circuit decision addressing ERISA plan status as a class member in a securities shareholder class action. As discussed in the article, the decision exposes a potential conflict among the...more

Employee Benefits Developments - November 2016

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of November, 2016. ACA Information Reporting – Bad News and Good News - First, the bad news: The 2016 final...more

Qualified Retirement Plan Amendments and IRS Filings — Upcoming Deadlines

This advisory reminds plan sponsors of deadlines for amending qualified retirement plans and for submitting certain plans to the IRS for a determination letter, as well as other significant changes to the determination letter...more

A Trump Presidency: Potential Impact on Employee Benefits Law and Policy

For many months, we have been speculating about how the results of the 2016 presidential election would impact employee benefits policy going forward. Now that Donald Trump has won the election and Republicans have secured a...more

IRS Releases Benefits and Contribution Limits for 2017

The Internal Revenue Service (IRS) recently issued its annual update regarding dollar limitations on contributions and benefits applicable to tax-qualified retirement and welfare plans for 2017. Please see full...more

Alert: IRS Announces Adjusted Plan Limits for 2017

The Internal Revenue Service has announced the 2017 limits that affect the operation of tax-qualified retirement plans, including 401(k) plans, and certain other types of employee benefit plans, including deferred...more

Recaps from Proskauer’s 21st Annual Trick of Treat Tax Exempt Seminar

Proskauer’s 21st Annual Trick or Treat Seminar was held on Thursday, October 27. The Seminar discussed: Best Practices for Document Retention: One Size Does Not Fit All...more

Employee Benefits Developments - October 2016

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of October, 2016. 2017 Benefits Limits Announced - The Internal Revenue Service and Social Security...more

IRS Announces 2017 Pension and Related Limitations

The Internal Revenue Service recently announced the dollar limitations for pension plans and other items beginning January 1, 2017. ...more

IRS Announces 2017 Retirement Plan Limitations – Most Limits Remain Unchanged

The Internal Revenue Service announced the 2017 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living...more

IRS Announces Employee Benefit Plan Limits for 2017

The Internal Revenue Service recently announced the cost-of-living adjustments to the applicable dollar limits for various employer-sponsored retirement and welfare plans for 2017. Although some of the dollar limits currently...more

2017 Cost of Living Adjustments for Retirement Plans

The Internal Revenue Service recently announced its cost-of-living adjustments applicable to dollar limitations for retirement plans and Social Security generally effective for Tax Year 2017 (see IR-2016-141). Most notably,...more

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