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IRS Takes the Position That No Statute of Limitations for ACA Employer Shared Responsibility Payments

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

Signing and Retaining Plan Documents is Crucial for Qualified Retirement Plans

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

Legislation Proposed to Allow Employers to Make Matching Contributions on Student Loan Repayments

Two bills have been introduced in the Senate that would allow employers to make matching contributions under 401(k), 403(b), governmental 457(b) and SIMPLE plans as if the participant’s student loan payments were salary...more

Holiday Stocking Stuffer: IRS Issues Proposed Regulations Under Code Section 162(m)

On December 16, 2019, the Treasury Department released proposed regulations (the “Proposed Regulations”) to address the amendments made to Code Section 162(m) by the Tax Cuts and Jobs Act (the “Amendment”). As background,...more

IRS Reopens Determination Letter Program for Certain Individually Designed Plans

In 2017, the IRS significantly limited the ability of plan sponsors to request a determination letter that its individually-designed retirement plan met the tax qualification requirements of the Internal Revenue Code. Since...more

IRS Issues Final Regulations on 401(k) Hardship Distributions

The Internal Revenue Service recently published final regulations modifying the rules relating to hardship distributions from Sections 401(k) and 403(b) plans. The final regulations reflect statutory changes affecting...more

Time to Restate Your 403B Plan

The Internal Revenue Service set March 31, 2020 as the last date of the remedial amendment period for tax-exempt organizations and public school systems to self-correct plan document defects in their Section 403(b) plans. ...more

IRS Announces 2020 Retirement Plan Limitations – Most Limits are Increased

The Internal Revenue Service announced the 2020 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

IRS Announces 2019 Retirement Plan Limitations – Certain Limits are Increased

The Internal Revenue Service announced the 2019 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

Tracking Tax Reform IRS Issues Initial Guidance Under Section 162(m)

On August 21, 2018, the IRS issued Notice 2018-68 providing initial guidance on the amendments made to Section 162(m) of the Internal Revenue Code of 1986 (the “Code”) by the 2017 tax reform bill, which has been renamed “To...more

IRS Announces 2018 Retirement Plan Limitations - Certain Limits are Increased

The Internal Revenue Service announced the 2018 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

Hurricane Harvey Relief for Employees and Employers

Employers seeking to ease the hardships faced by employees in the aftermath of Hurricane Harvey may be looking for ways to provide aid to their own workforces. Qualified Disaster Relief Payments - Generally, a payment...more

Locke Lord Article: House of Representatives Passes Legislation to Repeal and Replace The Affordable Care Act

On May 4, 2017, the House of Representatives passed the American Health Care Act (“AHCA”), the legislation to repeal and replace virtually all of the Affordable Care Act (“ACA”), by a vote of 217-213....more

IRS Announces 2017 Retirement Plan Limitations – Most Limits Remain Unchanged

The Internal Revenue Service announced the 2017 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

IRS Issues Proposed Regulations Affecting Deferred Compensation Plans of Tax-Exempt Organizations

On June 21, 2016, after more than 15 years of ongoing deliberations, the U.S. Department of the Treasury (the Dept. of Treasury) issued proposed regulations under Section 457 of the Internal Revenue Code of 1986 (the Code),...more

IRS Announces 2016 Retirement Plan Limitations – Most Limits Remain Unchanged

The Internal Revenue Service announced the 2016 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

Locke Lord QuickStudy: IRS Clarifies Performance-Based Compensation Exception Under Code Section 162(m)

On March 31, 2015, the Internal Revenue Service (IRS) published final regulations under Section 162(m) of the Internal Revenue Code (the Code). Code Section 162(m) disallows a deduction by any publicly-held corporation for...more

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