On September 26, 2022, the Internal Revenue Service issued Notice 2022-45, extending the deadline to amend eligible retirement plans (including nongovernmental qualified plans and 403(b) plans and individual retirement...more
The Internal Revenue Service (the “IRS”) recently issued Notice 2022-33 (the “Notice”), providing extensions to certain upcoming plan amendment deadlines under certain provisions of the Setting Every Community Up for...more
On May 18, 2021, the Internal Revenue Service (“IRS”) published Notice 2021-31 (the “IRS Notice”) containing detailed guidance relating to premium assistance for COBRA benefits under the American Rescue Plan Act of 2021...more
On March 26, 2021, the Internal Revenue Service (“IRS”) published Announcement 2021-7, which notifies taxpayers that certain amounts paid for personal protective equipment (such as masks, hand sanitizer, and sanitizing wipes)...more
On February 26, 2021, the DOL issued guidance regarding the impact of that statutory limitation on the previously announced deadline extensions, in EBSA Disaster Relief Notice 2021-01.
Disaster Relief Notice 2021-01, in...more
On February 18, 2021, the IRS issued Notice 2021-15, which provides guidance with regard to a number of provisions of the temporary changes to the rules related to the operation of health and dependent care flexible spending...more
On December 9, 2020, the Internal Revenue Service (“IRS”) issued Notice 2020-86 which provides guidance relating to certain changes to the safe harbor rules that apply to 401(k) plans made by the Setting Every Community Up...more
The IRS recently issued IRS Notice 2020-50 (“Notice 2020-50”) which provides guidance for retirement plan sponsors and administrators, as well as to individuals, relating to the application of coronavirus-related...more
The Internal Revenue Service (“IRS”) recently issued Notice 2020-29 and Notice 2020-33 which allow employers to provide various new types of relief to employees participating in Section 125 cafeteria plans (including flexible...more
On April 28, 2020, the Employee Benefits Security Administration, the Department of Labor, the Internal Revenue Service, and the Department of the Treasury (the “Agencies”) signed a joint notification of relief, which was...more
Over the past few weeks, the Internal Revenue Service (“IRS”) has provided relief to taxpayers impacted by the COVID-19 pandemic, by extending the deadline for payment and filing of individual income tax returns from April...more
On September 23, 2019, the Department of Treasury published the final regulations relating to changes to the hardship distribution rules that apply to qualified retirement plans and 403(b) plans, that were enacted under the...more
The IRS announced (through the two announcements 2017-11 and 2017-13) relief for victims of Hurricane Harvey, which struck Texas and surrounding areas in August 2017, and victims of Hurricane Irma, which struck Florida and...more
9/27/2017
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Tax Returns
In January 2017, the IRS published Revenue Procedure 2017-18 which set March 31, 2020 as the last day to take advantage of the remedial amendment period under Revenue Procedure 2013-22 to retroactively fix defects in 403(b)...more
The Internal Revenue Service recently released long anticipated proposed regulations (the “Proposed Regulations”) governing deferred compensation arrangements maintained by tax-exempt organizations and governmental entities...more
7/29/2016
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Tax Exempt Entities
As the federal agencies continue to issue more guidance on the application of various provisions of the Affordable Care Act (the “ACA”) to employer-sponsored health coverage, there are some recent developments that we want to...more
Under so-called “employer payment plans” (“EPPs”), an employer pays or reimburses an employee for substantiated premium costs under individual health plan insurance coverage (i.e., nonemployer individual health plan...more
As mentioned in a prior Alert, beginning in 2013 employees’ salary reduction contributions to a health flexible spending account (health FSA) may not exceed $2,500 per plan year. This limit is to be indexed for inflation in...more
As the federal government agencies continue to push forward with implementation and administration of health care reform (i.e., the Patient Protection and Affordable Care Act), there are two recent developments that we want...more
On June 26, 2013, the U.S. Supreme Court, in the landmark case, United States v. Windsor, found the provisions of that portion of the “Defense of Marriage Act” (“DOMA”) which provided that only opposite-sex individuals could...more
Recent guidance from the IRS modifies the long-standing “use or lose it” rule under a health flexible spending arrangement (“Health FSA”) to permit such arrangements to offer participants the opportunity to carryover up to...more
Earlier this summer we sent you an Alert concerning the U.S. Supreme Court’s historic ruling (United States v. Windsor) regarding same-sex marriage. This decision declared, as unconstitutional, Section 3 of the federal...more
On July 9, 2013, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued formal guidance (IRS Notice 2013-45; herein, the “Notice”)1 that provides for a one year delay until 2015 with respect to (i) certain...more
Recognizing that the requirement to have a detailed written plan document for a 403(b) retirement plan was a new and arduous task for many non-profit entities who sponsored such plans, the IRS has now published favorable...more
In This Alert:
- A. What Is The Employer Shared Responsibility Penalty?
- What Is The “Failure To Offer Coverage Penalty”?
- How Is The “Failure To Offer Coverage Penalty” Calculated?
- What Is...more