The Internal Revenue Code generally discourages retirement plan participants from requesting distributions from their retirement plan funds prior to age 59 ½ by imposing an additional 10% tax on those distributions. However,...more
The IRS recently issued Notice 2024-02— dubbed the “Grab Bag Notice”— which addresses multiple provisions in SECURE 2.0. The guidance is 81 pages long, comes in the form of frequently asked questions and answers, and speaks...more
1/26/2024
/ 401k ,
Benefit Plan Sponsors ,
CARES Act ,
Distribution Rules ,
Employee Benefits ,
IRS ,
Pension Plan Amendments ,
Retirement Plan ,
Safe Harbors ,
SECURE Act ,
Tax Credits
The IRS and the U.S. Department of Labor recently issued guidance which addresses the newly created Pension Linked Emergency Savings Accounts (“PLESAs”), a novel plan design option authorized under SECURE 2.0. PLESAs are...more
On August 25, 2023, the IRS issued Notice 2023-62 to address certain industry concerns over implementation of Section 603 of the SECURE 2.0 Act. Section 603 relevantly provides that, beginning in 2024, participants eligible...more
The SECURE 2.0 Act includes a substantial expansion of the Employee Plans Compliance Resolution System (EPCRS), the IRS umbrella program for correction of retirement plan defects. It also requires EPCRS to be updated to...more
Earlier this week, the government released Revenue Procedure 2023-23 outlining the 2024 inflation adjusted limits for health savings accounts (HSAs) and high deductible health plans (HDHPs). An HSA is a tax-advantaged way for...more
Plan sponsors of individually designed 403(b) plans will soon be able to submit determination letter applications to the IRS. (Individually designed plans are plans using custom documents that have not been preapproved...more
The Internal Revenue Service recently issued its annual cost-of-living adjustments (COLAs) for the 2023 tax year for retirement plans as well as health and welfare benefit plans. These COLAs reflect significant...more
The IRS has extended additional deadlines for required retirement plan amendments, similar to the extensions we discussed last month found here. Notice 2022-45 extends the deadline for amending qualified retirement plans to...more
9/30/2022
/ 403(b) Plans ,
457(b) Plans ,
Benefit Plan Sponsors ,
CARES Act ,
Employee Benefits ,
Filing Deadlines ,
IRS ,
Pension Plan Amendments ,
Qualified Retirement Plans ,
Retirement Plan ,
SECURE Act ,
Time Extensions
The IRS has extended additional deadlines for required retirement plan amendments, similar to the extensions we discussed last month found here. Notice 2022-45 extends the deadline for amending qualified retirement plans to...more
9/30/2022
/ 403(b) Plans ,
457(b) Plans ,
Benefit Plan Sponsors ,
CARES Act ,
Employee Benefits ,
Filing Deadlines ,
IRS ,
Pension Plan Amendments ,
Qualified Retirement Plans ,
Retirement Plan ,
SECURE Act ,
Time Extensions
The IRS has issued a notice extending the deadline for retirement plan sponsors to make certain amendments required by recently passed legislation. Notice 2022-33 extends the deadline for amending qualified retirement plans...more
The American Rescue Plan Act of 2021 (the "ARPA") brings back COBRA subsidies (previously available in modified form under the American Recovery and Reinvestment Act of 2009) starting April 1, 2021, and requires employers and...more
3/19/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
Biden Administration ,
COBRA ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
IRS ,
Notice Requirements ,
Premium Subsidies ,
Relief Measures
The Internal Revenue Service (“IRS”) has issued two important notices allowing employer-plan sponsors to amend their §125 cafeteria plans to provide employees with increased flexibility for elected benefits and account...more
5/20/2020
/ Cafeteria Plans ,
Coronavirus/COVID-19 ,
Dependent Care Assistance Program (DCAP) ,
Employee Benefits ,
Employer Group Health Plans ,
Flexible Spending Accounts ,
HDHP ,
Health Insurance ,
HRA ,
IRS ,
Relief Measures
Employer-sponsors of certain retirement plans have work to do prior to the end of 2019. Sponsors of Internal Revenue Code ("Code") section 401(k) and 403(b) plans must analyze their plan documents and associated...more
8/25/2019
/ 401k ,
403(b) Plans ,
Benefit Plan Sponsors ,
Employee Benefits ,
Hardship Distributions ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Popular ,
Proposed Regulation ,
Retirement Plan ,
Safe Harbors ,
U.S. Treasury
In the constantly evolving legal framework surrounding employee benefit plans, maintaining a retirement plan's qualified status can be a daunting task for plan administrators and plan sponsors. The Internal Revenue Service...more
Given the increased scrutiny that the Internal Revenue Service (IRS) is giving to §403(b) plans and an upcoming deadline for adopting a "safe harbor plan," now is a good time for sponsors of §403(b) plans to ensure that their...more