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DOL Amends Fiduciary Advice Definition Regulation 

On April 23, 2024, the U.S. Department of Labor (“DOL” or “Department”) issued a final regulatory package amending its fiduciary investment advice regulation and revising numerous existing prohibited transaction exemptions...more

IRS Announces Intention to Issue Guidance on NFTs

On March 21, 2023, the Department of Treasury (“Treasury”) and Internal Revenue Service (“IRS”) released Notice 2023-27, which announced that Treasury and the IRS intend to issue guidance related to the treatment of certain...more

Recent IRS Guidance Focuses on Rules for Qualified Foreign Pension Funds

At the end of 2022, the Department of the Treasury and the Internal Revenue Service (together, the “IRS”) issued two sets of guidance – a final rule and a proposed rule – addressing the application of certain provisions of...more

IRS Guidance on Excise Tax on Buybacks Clarifies Some Benefits Issues

New Section 4501 of the Internal Revenue Code imposes a 1% excise tax on certain corporate stock repurchases or “corporate buybacks” in excess of $1 million in the taxable year.  The new tax is imposed on the fair market...more

Proposed “One-Bad-Apple” Rules – IRS Takes Another Cut

On March 25, the IRS issued a set of proposed regulations under Internal Revenue (“Code”) section 413(c) and 413(e) addressing multiple employer plans, or “MEPs,” and pooled employer plans, or “PEPs.” 87 Fed. Reg. 17225. We...more

DOL Proposes to Significantly Tighten Prohibited Transaction Exemption Procedures

Over the decades since the enactment of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), many plan sponsors, service providers, and industry groups have applied for, and been granted, prohibited...more

IRS Issues Final Regulations Updating Minimum Required Distribution Rules

On November 5, 2020, the Internal Revenue Service (“IRS”) released final regulations under section 401(a)(9) of the Internal Revenue Code (“IRC”). 85 Fed. Reg. 72472 (Nov. 12, 2020). The final regulations, which closely...more

IRS and PBGC Give Sponsors Until January 4, 2021 to Make Contributions Under the CARES Act

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) passed earlier this year delayed the due date of quarterly and final contributions otherwise due in calendar year 2020 to January 1, 2021. But because...more

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