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2026 Inflation-Adjusted Health and Welfare Plan Limits

On May 1, 2025, the IRS released Rev Proc 2025-19 which updated for 2026 the limits applicable to certain health and welfare plans, including the following key limits...more

IRS Issues Proposed Regulations on Secure 2.0 Catch-Up Provisions

The IRS issued Proposed Regulations last month which provide helpful clarity for employers on how to implement and comply with two new SECURE 2.0 provisions relating to catch-up contributions....more

2025 Inflation-Adjusted Plan Limits

On Nov. 1, 2024, the IRS published its annual cost of living adjustments for various retirement plan limits. These increases are more modest than recent years, a reflection that inflation is slowing....more

IRS Weighs in on Inadvertent Benefit Overpayments

Earlier this week, the IRS released Notice 2024-77, which provides much-anticipated guidance related to the handling of so-called “inadvertent benefit overpayments” from qualified retirement plans under the SECURE 2.0 Act. ...more

IRS Issues FAQs Regarding Long-Term Part-Time Employees in 403(b) Plans

The IRS recently issued Notice 2024-73, which provides much-needed guidance on long-term, part-time (“LTPT”) employees in ERISA-governed 403(b) retirement plans. Following passage of the SECURE 2.0 Act, an employee is...more

IRS Issues Guidance on New Exceptions to 10% Additional Tax on Early Distributions from Retirement Plans

The Internal Revenue Code generally discourages retirement plan participants from requesting distributions from their retirement plan funds prior to age 59 ½ by imposing an additional 10% tax on those distributions. However,...more

IRS Issues Grab Bag Notice Addressing Various SECURE 2.0 Provisions

The IRS recently issued Notice 2024-02— dubbed the “Grab Bag Notice”— which addresses multiple provisions in SECURE 2.0. The guidance is 81 pages long, comes in the form of frequently asked questions and answers, and speaks...more

Federal Agencies Issue PLESA Guidance

The IRS and the U.S. Department of Labor recently issued guidance which addresses the newly created Pension Linked Emergency Savings Accounts (“PLESAs”), a novel plan design option authorized under SECURE 2.0. PLESAs are...more

IRS Delays Roth Catch-Up Requirement for High Earners

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

IRS Issues Notice Regarding Expansion of EPCRS under SECURE 2.0 Act

The SECURE 2.0 Act includes a substantial expansion of the Employee Plans Compliance Resolution System (EPCRS), the IRS umbrella program for correction of retirement plan defects. It also requires EPCRS to be updated to...more

Individually Designed 403(b) Plans will be Eligible for Determination Letters

​​​​​​​Plan sponsors of individually designed 403(b) plans will soon be able to submit determination letter applications to the IRS. (Individually designed plans are plans using custom documents that have not been preapproved...more

Sizeable Increases to 2023 Plan Limits Due to Inflation

​​​​​​​The Internal Revenue Service recently issued its annual cost-of-living adjustments (COLAs) for the 2023 tax year for retirement plans as well as health and welfare benefit plans. These COLAs reflect significant...more

IRS Delays Additional Amendment Deadlines for Major Retirement Legislation

The IRS has extended additional deadlines for required retirement plan amendments, similar to the extensions we discussed last month found here. Notice 2022-45 extends the deadline for amending qualified retirement plans to...more

IRS Delays Additional Amendment Deadlines for Major Retirement Legislation

The IRS has extended additional deadlines for required retirement plan amendments, similar to the extensions we discussed last month found here. Notice 2022-45 extends the deadline for amending qualified retirement plans to...more

IRS Delays Amendment Deadlines for Major Retirement Legislation

The IRS has issued a notice extending the deadline for retirement plan sponsors to make certain amendments required by recently passed legislation. Notice 2022-33 extends the deadline for amending qualified retirement plans...more

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