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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

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

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

SECURE 2.0: Broad Bipartisan Retirement Reform Finally Crosses the Finish Line

​​​​​​​Eagerly anticipated comprehensive retirement plan legislation commonly known as the "SECURE 2.0 Act" was signed into law on December 30, 2022, as part of the Consolidated Appropriations Act of 2023. The changes made by...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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