When the SECURE Act was passed in late 2019 and the CARES Act in Spring 2020, retirement plans were expected to adopt appropriate amendments by the end of 2022. While the IRS in Notice 2022-33 and Notice 2022-45 extended the...more
The Internal Revenue Service (IRS) has issued temporary relief for sponsors of safe harbor retirement plans considering reduction or suspension of safe harbor contributions due to COVID 19. ...more
The IRS has significantly expanded the categories of "qualified individuals" who can receive distributions and loans with favorable tax treatment to include individuals who have suffered a pay cut and those whose spouses and...more
The Internal Revenue Service (IRS) has issued temporary relief with respect to the requirement that certain retirement plan participant elections must be witnessed in the physical presence of a plan representative or notary...more
ERISA requires Summary Plan Descriptions and other disclosures to be "written in a manner calculated to be understood by the average plan participant." ERISA section 102(a). ...more
In a previous blog, we discussed the potential changes under the Setting Every Community Up for Retirement Enhancement (SECURE) Act of interest to plan participants. ...more
Our previous Advisory on the Tax Cuts and Jobs Act reported that it made few changes that affected retirement plans. However Congress got another chance in the recent Bipartisan Budget Act of 2018, and included changes to...more
As it did last year, the IRS has again extended the date that employer Form 1095-C reports need to be distributed to employees. For 2017 reports, the deadline is now March 2, 2018, but the deadline for filing the reports with...more
After months of Congressional attempts to “repeal and replace” the ACA ended in failure, President Trump has issued an Executive Order and taken other actions that could significantly reshape the health care market. We are...more
The IRS has extended the relief available to employers who offer an “opt-out” payment to employees who decline company medical coverage. This means that for 2017, such payments, whether conditional or unconditional, will not...more
This alert concerns the extension of the deadline for distributing and filing Forms 1094 and 1095.
If you were not already aware, the IRS announced in Notice 2016-70 that the deadline for employers to distribute ACA...more
The IRS has issued new guidance giving sponsors of Safe Harbor 401(k) plans much greater flexibility to amend their plans during a plan year. This is welcome relief from the previous IRS position that had hobbled such plans....more
The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more
New IRS guidance adds two more events that allow participants to change their cafeteria plan elections outside of the annual open enrollment period. These events are designed to coordinate with the employer coverage rules and...more
The IRS has announced new, long-requested relief from the “use it or lose it” rule that will allow health flexible spending account (FSA) participants to carry over up to $500 of unused contributions to the next plan year if...more
The IRS recently released new proposed regulations to implement the Shared Responsibility or “Play or Pay” provisions of Health Care Reform. The proposed regulations provide a wealth of detail on key issues required to...more