On June 20, 2024, the Internal Revenue Service (“IRS”) released Notice 2024-55 (the “Notice”) offering guidance on two (2) new types of distributions exempt from the 10% early withdrawal penalty: emergency personal expense...more
In late December 2023, approximately one year after Congress enacted the Setting Every Community Up for Retirement Enhancement Act of 2022 (“SECURE 2.0”), the Internal Revenue Service (the “IRS”) released Notice 2024-2 (the...more
The Internal Revenue Service (“IRS”) recently released proposed regulations addressing the eligibility requirements for long-term, part-time (“LTPT”) employees to participate in employer-sponsored 401(k) plans. Rules...more
The Internal Revenue Service announced the 2024 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living...more
The Department of the Treasury and Internal Revenue Service recently issued proposed regulations (the “Proposed Regulations”) relating to forfeitures in 401(k) plans and other tax-qualified retirement plans. Forfeitures...more
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On February 27, 2023, the Department of the Treasury (“Treasury”) and Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) relating to forfeitures in tax-qualified...more
The Internal Revenue Service announced the 2023 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living...more
On September 26, 2022, the Internal Revenue Service issued IRS Notice 2022-45, which extends the deadline for amending retirement plans to reflect certain optional and required changes under the Coronavirus Aid, Relief, and...more
On August 3, 2022, the Internal Revenue Service issued IRS Notice 2022-33, which extends the deadline for amending certain plans with the applicable requirements of the Setting Every Community Up for Retirement Enhancement...more
In its June 3, 2022 Employee Plans Newsletter, the IRS announced a pilot pre-examination retirement plan compliance program beginning in June 2022. Under the pilot program, the IRS will notify a qualified plan sponsor by...more
The Internal Revenue Service announced the 2022 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living...more
The IRS recently issued Revenue Procedure 2021-30, which updates the correction program under the Employee Plans Compliance Resolution System (EPCRS). EPCRS permits plan sponsors to correct failures in the form and operation...more
On May 18, 2021, the Internal Revenue Service issued Notice 2021-31 (the “Notice”) providing much anticipated guidance on implementing the COBRA subsidy provisions under the American Rescue Plan Act (the “Act”). ...more
The Internal Revenue Service recently announced that it will treat contributions to single-employer defined benefit pension plans, previously extended to January 1, 2021 by the CARES Act, as timely if made no later than...more
The economic uncertainty of the COVID-19 pandemic has forced many employers to furlough or layoff a significant percentage of their workforce. Among the issues an employer should consider in a furlough or layoff context is...more
The Internal Revenue Service announced the 2021 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living...more
The economic uncertainty of the COVID-19 pandemic has forced many employers to furlough or layoff a significant percentage of their workforce. These workforce reductions may inadvertently cause a “partial termination” of the...more
On August 8, 2020, President Trump issued the Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster (the “Executive Order”). The Executive Order instructed the Treasury...more
On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more
The Internal Revenue Service (IRS) issued helpful guidance to plan sponsors of safe harbor 401(k) plans that are considering reducing or suspending safe harbor employer matching contributions or safe harbor nonelective...more
The Internal Revenue Service (IRS) recently issued Notice 2020-50 which provides helpful guidance for plan sponsors and plan participants who wish to take advantage of the enhanced distribution and loan provisions under the...more
6/29/2020
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As employers and employees adjust to the changes caused by this unprecedented global pandemic, preserving access to and protecting elections under group health and welfare plans are hot topics on many minds. To further assist...more
In response to the COVID-19 pandemic, the IRS has automatically extended the deadline for certain retirement and welfare plans to file Form 5500. IRS Notice 2020-23 provides that tax returns, including Forms 5500, that are...more
In a surprising memo from the IRS Office of Chief Counsel, the IRS concluded that there is no statute of limitations period on the Employer Shared Responsibility Payments (“ESRP”) under the Affordable Care Act. The IRS...more
A recent Chief Counsel Memorandum (“CCM”) makes clear that a qualified retirement plan can face disqualification if the plan sponsor cannot provide a copy of an executed plan document or plan amendment upon audit....more