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IRS Extends Anticipated Effective Date for Certain 2024 Proposed RMD Rules Until 2026

Last year, the IRS issued its long-anticipated final (and newly proposed) regulations to address SECURE 1.0 and 2.0 Act changes to the required minimum distribution (“RMD”) rules (Code section 401(a)(9)). The 2024 proposed...more

IRS Finalizes (and Proposes More) Required Minimum Distribution Rules

At long last, the Treasury Department and the Internal Revenue Service (“IRS”) issued final (and new proposed) regulations that address the major changes to Code section 401(a)(9) under the Setting Every Community Up for...more

Additional Required Minimum Distribution Relief Following SECURE 2.0 Act Changes

Last week, the IRS issued Notice 2023-54 (“Notice”) that provides a variety of relief for both plan sponsors and IRA providers, along with participants/IRA owners and their beneficiaries, while we await the final Code section...more

IRS Updates LRMs for 403(b) Plans

The IRS recently issued an updated Listing of Required Modifications and Information Package (known as the “LRMs”) for 403(b) plans. These LRMs contain quite a few changes, from simple clarifications and explanatory notes,...more

IRS Revamps Minimum Required Distribution Rules

At long last, the Internal Revenue Service issued proposed regulations under Code section 401(a)(9) that take into account the major changes made by the Setting Every Community Up for Retirement Enhancement Act of 2019...more

IRS Updates Safe Harbor Methods for “Substantially Equal Periodic Payment” Exception

Recent IRS Notice 2022-6 updates longstanding guidance on when a series of payments from an individual account under a tax-favored retirement plan is considered a series of “substantially equal periodic payments”. Under Code...more

Updated IRS Publication 590-B Provides Insights On Post-Death RMD Rules After the SECURE Act

While we await proposed regulations under Code section 401(a)(9) to reflect the significant changes made to the required minimum distribution (“RMD”) rules under the SECURE Act, the 2020 IRS Publication 590-B for IRA...more

Church Plans Under the SECURE Act

Many of the provisions of the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”) do not apply to non-electing church plans, but some do, notably those dealing with certain 403(b)(9) plans and...more

SECURE Act Requires Immediate Action by Plan Service Providers

Congress recently passed the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), the largest package of retirement system reforms in over a decade.  Many of the provisions in the SECURE Act...more

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