News & Analysis as of

Retirement Plan Internal Revenue Service Employee Contributions

McGuireWoods LLP

IRS Gives Guidance on Student Loan Payment Matching Contributions

McGuireWoods LLP on

IRS Notice 2024-63, published Aug. 19, 2024, provides interim guidance for plan sponsors on the SECURE 2.0 Act provision permitting employers to offer matching contributions to their retirement plans — including 401(k) and...more

Jackson Lewis P.C.

Use of Plan Forfeitures Not the Slam Dunk It Used to Be

Jackson Lewis P.C. on

A recent rash of class action lawsuits in California claim that using forfeitures to reduce future employer contributions to tax-qualified retirement plans runs afoul of the Employee Retirement Income Security Act (ERISA)....more

Morgan Lewis

Final 417(e) Regulations Add New Requirements and Offer Design Flexibility

Morgan Lewis on

The US Internal Revenue Service (IRS) recently issued final regulations concerning “minimum present value requirements” for tax-qualified defined benefit plans (DB plans). There are three primary changes for sponsors of DB...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

Groom Law Group, Chartered

Final IRS Regulations Update Present Value Calculations for Defined Benefit Plans and Expand Anti-Cutback Relief

Generally, a defined benefit plan provides an accrued benefit commencing at a participant’s Normal Retirement Date that pays a flat benefit over the lifetime of the participant. If a plan provides for a distribution as a...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

Seyfarth Shaw LLP

“SECURE-ing” the Answers to Outstanding Questions on the Rothification of Employer Contributions

Seyfarth Shaw LLP on

Seyfarth Synopsis: Under Section 604 of Secure 2.0, sponsors of 401(k), 403(b) and governmental plans may allow employees to designate employer match (including match on student loan repayments) or nonelective contributions...more

Roetzel & Andress

IRS Issues Proposed Regulations on Long-Term, Part-Time Employees

Roetzel & Andress on

Historically, qualified retirement plans have excluded part-time employees from participation. An employer’s ability to do so has now been limited by the Setting Every Community Up for Retirement Enhancement Act (“SECURE...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

Foster Swift Collins & Smith

IRS Announces 2024 Cost-of-Living Adjustments for Retirement Plans and for Health and Welfare Benefit Plans

The IRS has announced the 2024 cost-of-living adjustments for retirement plan and health and welfare benefit plan limitations. The charts below set forth the applicable limitations. Retirement Plans - Similar to...more

Pullman & Comley - Labor, Employment and...

IRS Delays Roth Catch-Up Requirement for Certain Higher-Paid Employees

Our August 24, 2023 blog post “Retirement Plans:  Will January 1, 2024 Effective Date for Age 50 Catch-Up Contribution Changes Be Delayed?,” discussed the new catch-up contribution rule and options for keeping retirement...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

Kohrman Jackson & Krantz LLP

Treasury Provides Temporary Relief from 401(k) Catch-up Contributions Rollback - Update

The Secure 2.0 Act (Secure 2.0), a sweeping retirement bill included in Division T of the Consolidated Appropriations Act of 2023, was a major bipartisan accomplishment of the 117th Congress. The bill included 82 provisions...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

Foley & Lardner LLP

And The Crowd Goes Wild: IRS Delays SECURE 2.0 Roth Catch-Up Rule Until 2026

Foley & Lardner LLP on

While most of the country was gearing up for the U.S. Open, retirement plan sponsors and service providers collectively celebrated a big win on August 25 when the IRS delayed the new Roth catch-up rule until January 1, 2026. ...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

Best Best & Krieger LLP

New Guidance - Secure 2.0 Roth Treatment of Catch-up Contributions

On August 25, 2023 the Internal Revenue Service issued Notice 2023-62, which provides a critical 2-year delay in the enforcement of new retirement plan Catch-up Contributions rules passed under the Secure 2.0 Act of 2022....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

Epstein Becker & Green

SECURE 2.0: Roth Catch-Up Contribution Delay

Section 603 of the SECURE 2.0 Act of 2022 (“Section 603”) implements changes to catch-up contributions and is applicable to employers who maintain a 401(k), 403(b), or 457(b) plan with participants who are age 50 and older...more

Verrill

Catch-Up Contributions: IRS Provides Relief from Roth Requirements of SECURE 2.0

Verrill on

On August 25, 2023, the IRS issued IRS Notice 2023-62, providing much needed relief for employers who have been struggling to implement Section 603 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”), which requires high income...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

Warner Norcross + Judd

IRS Delays Roth Catch-up Requirement to 2026

Warner Norcross + Judd on

The SECURE Act 2.0, enacted on December 29, 2022, is the most significant piece of legislation affecting retirement plans in many years. One provision in the Act causing headaches for plan sponsors, payroll providers and...more

Quarles & Brady LLP

IRS Extends Compliance Date for Roth Catch-up Contributions Until Jan. 1, 2026

Quarles & Brady LLP on

Section 603 of the SECURE 2.0 Act of 2022 (SECURE 2.0) requires that catch-up contributions for individuals whose wages exceed $145,000 are subject to mandatory Roth tax treatment effective as of January 1, 2024. Due to the...more

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