Prior to the enactment of Section 409A, no single section of the Internal Revenue Code governed taxation of nonqualified deferred compensation. Income inclusion of deferred compensation was historically governed by a variety...more
Connecticut employers faced a year of significant legal and regulatory developments in 2025. Spanning from January through June, Pullman & Comley’s Working Together Webinar Series delivered timely insights into the most...more
1/5/2026
/ Americans with Disabilities Act (ADA) ,
Artificial Intelligence ,
Collective Bargaining ,
Employee Benefits ,
Employee Monitoring ,
Employees ,
Employer Liability Issues ,
Labor Reform ,
New Legislation ,
Paid Sick Leave ,
Paid Time Off (PTO) ,
Reasonable Accommodation ,
State Labor Laws ,
Wage and Hour
The Internal Revenue Service and the Social Security Administration have announced the cost of living adjustments (COLA) applicable to dollar limitations for retirement plans and the Social Security wage base for 2026. ...more
11/25/2025
/ 401k ,
403(b) Plans ,
457(b) Plans ,
Cost-of-Living Adjustment (COLA) ,
Defined Benefit Plans ,
Defined Contribution Plans ,
Employee Benefits ,
Highly Compensated Employees ,
Internal Revenue Code (IRC) ,
IRS ,
Retirement Plan ,
Social Security
Many employers sponsor Section 401(k) Plans to help employees save for retirement by allowing them to contribute a portion of their pay into the Plan. ...more
10/28/2025
/ 401k ,
Benefit Plan Sponsors ,
Compliance Dates ,
Defined Contribution Plans ,
Employee Benefits ,
Employer Responsibilities ,
Internal Revenue Code (IRC) ,
IRS ,
Plan Participants ,
Regulatory Requirements ,
Retirement Plan
Participants in Section 401(k), Section 403(b) and governmental Section 457(b) Plans who are age 50 or older are able to make salary deferrals in excess of the limit on salary deferrals for younger participants. These...more
9/22/2025
/ 401k ,
403(b) Plans ,
457(b) Plans ,
Employee Benefits ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Retirement Plan ,
Roth IRA ,
SECURE Act ,
U.S. Treasury
The recent federal district court decision in Faulk Company, Inc. v. Xavier Becerra, et al., No. 24-cv-00609-P (N.D. Tex. 2025) significantly alters the primary mechanism used by the U.S. Department of Health and Human...more
6/23/2025
/ Affordable Care Act ,
Appeals ,
Compensation & Benefits ,
Corporate Counsel ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employer Liability Issues ,
Enforcement ,
Health Insurance ,
IRS ,
Judicial Authority ,
Regulatory Requirements ,
Shared Responsibility Rule ,
Statutory Interpretation ,
Tax Liability
The IRS has announced the 2026 cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and excepted benefit health reimbursement arrangements...more
5/9/2025
/ Affordable Care Act ,
Compensation & Benefits ,
Cost-of-Living Adjustment (COLA) ,
Employee Benefits ,
HDHP ,
Health Insurance ,
Healthcare ,
HRA ,
HSA ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Revenue Procedures ,
Taxation
Certain transactions between employee benefit plans and “parties in interest” are prohibited under the Employee Retirement Income Security Act of 1974, as amended (ERISA). ...more
5/7/2025
/ 401k ,
Compensation & Benefits ,
Cunningham v Cornell University ,
Employee Benefits ,
ERISA Litigation ,
Excessive Fees ,
Fiduciary Duty ,
Litigation Strategies ,
Prohibited Transactions ,
Real Party in Interest ,
Retirement Plan ,
SCOTUS ,
Third-Party Service Provider ,
TPAs
Many employer-sponsored defined contributions plans, including 401(k) profit sharing plans and money purchase pension plans include a vesting schedule – a period over which a plan participant earns a nonforfeitable right to...more
2/3/2025
/ 401k ,
Benefit Plan Sponsors ,
Breach of Duty ,
Compensation & Benefits ,
Corporate Counsel ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Contributions ,
Employment Litigation ,
ERISA Litigation ,
Fiduciary Duty ,
Financial Services Industry ,
Pensions ,
Plan Administrators ,
Profit Sharing ,
Prohibited Transactions ,
Retirement Plan
Since 2002, employers have been able to make catch-up salary deferrals to their employees in their 401(k), 403(b), and governmental 457(b) plans beginning in the calendar year in which they turn 50 (the “Age 50 Catch-up”)....more
The Secure 2.0 Act of 2022 authorizes numerous new provisions that employers can choose to include or exclude in the retirement plans they sponsor. Recently, retirement plan vendors (vendors) have been sending communications...more
8/2/2024
/ Benefit Plan Sponsors ,
Compensation & Benefits ,
Deadlines ,
Employee Benefits ,
Financial Services Industry ,
Hospitality Industry ,
Investment Management ,
Opt-In ,
Opt-Outs ,
Restaurant Industry ,
Retirement ,
Retirement Plan ,
SECURE Act
The Internal Revenue Service and the Social Security Administration have announced the cost of living adjustments (COLA) applicable to dollar limitations for retirement plans and the Social Security wage base for 2024. Many...more
2/12/2024
/ 401k ,
403(b) Plans ,
457(b) Plans ,
Compensation & Benefits ,
Contribution Limits ,
Cost-of-Living Adjustment (COLA) ,
Employee Benefits ,
Internal Revenue Code (IRC) ,
IRS ,
Retirement Plan ,
Tax Planning
On December 20, 2023, the Internal Revenue Service (IRS) issued Notice 2024-2 to “provide guidance on discreet issues” concerning the implementation of specific provisions of the SECURE 2.0 Act of 2022 (SECURE 2.0)....more
1/12/2024
/ 403(b) Plans ,
457(b) Plans ,
Compensation & Benefits ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
IRS ,
Qualified Retirement Plans ,
Regulatory Requirements ,
Retirement ,
Retirement Plan ,
SECURE Act ,
Tax Planning
Student loan debt is a significant source of financial stress for borrowers, who face a hefty new line item in their budgets since the pause on student loan repayment ended in October 2023. Recent surveys show that student...more
1/10/2024
/ 401k ,
403(b) Plans ,
457(b) Plans ,
Compensation & Benefits ,
Employee Benefits ,
Employees ,
Employer Contributions ,
Loan Repayment Issues ,
Retirement Plan ,
SECURE Act ,
Student Loans
The Medicare Secondary Payer provisions (MSP) apply to group health plans sponsored by employers with 20 or more employees, in both the private and public sectors. MSP’s mandatory reporting requirements are designed to...more
Section 401(k) Plans, Section 403(b) Plans and governmental Section 457(b) Plans generally permit employees to defer compensation on a pre-tax basis. These plans may also provide the opportunity for employees to defer...more
8/25/2023
/ 401k ,
403(b) Plans ,
457(b) Plans ,
Compensation & Benefits ,
Deferred Compensation ,
Employee Benefits ,
Employee Contributions ,
Employees ,
Individual Retirement Account (IRA) ,
Regulatory Agenda ,
Regulatory Reform ,
Retirement Plan ,
Roth IRA ,
SECURE Act ,
Tax Liability
Our July 14, 2023 Client Alert discussed the information and documents that Connecticut Public Act 23-182 requires municipalities sponsoring retirement plans to provide to the Comptroller’s Office by September 1, 2023. On...more
8/3/2023
/ 457(b) Plans ,
Connecticut ,
Defined Benefit Plans ,
Defined Contribution Plans ,
Employee Benefits ,
Labor Reform ,
Municipal Employees ,
Municipalities ,
Public Acts ,
Regulatory Requirements ,
Retirement Plan ,
State-Sponsored Retirement Plans ,
Surveys
August 31, 2023 is the deadline to register your business for the state-sponsored employee retirement savings program MyCTSavings.
If you currently sponsor a retirement plan that complies with the requirements of...more
In a June 7, 2023 press release, State of Connecticut Comptroller Sean Scanlon applauded the passage of House Bill No. 6930, which aspires to develop best practices for governance structures of municipal retirement plans....more
7/17/2023
/ Compensation & Benefits ,
Connecticut ,
Employee Benefits ,
Financial Services Industry ,
Investment ,
Municipalities ,
Public Acts ,
Regulatory Requirements ,
Reporting Requirements ,
Retirement ,
Retirement Plan
Since 1998 the Internal Revenue Services (the “IRS”) has had a comprehensive employees plans correction program with three components: self-correction (SCP), voluntary correction with IRS approval including related user fee...more
The SECURE 2.0 Act of 2022 (SECURE 2.0), enacted on December 29, 2022 as part of the Consolidated Appropriations Act of 2023, will impact retirement plan operations for years to come. Some provisions were effective as of the...more
Section 457(b) Plans provided by Tax-Exempt employers for their highly compensated employees and/or a select group of management employees (“Tax-Exempt 457(b) Plans”) are subject to required minimum distribution rules under...more
12/2/2022
/ 457(b) Plans ,
Charter Schools ,
Compensation & Benefits ,
Deadlines ,
Employee Benefits ,
Highly Compensated Employees ,
Internal Revenue Code (IRC) ,
IRS ,
Private Schools ,
Required Minimum Distributions ,
Retirement Plan ,
SECURE Act ,
Tax Exempt Entities
Section 457(b) Plans provided by Tax-Exempt employers for their highly compensated employees and/or a select group of management employees (“Tax-Exempt 457(b) Plans”) are subject to required minimum distribution rules under...more
Retirement plans and individual retirement accounts (IRAs) are subject to required minimum distribution rules under Internal Revenue Codes Section 401(a)(9). The SECURE Act amended the required minimum distribution rules...more
In June 2022, the HHS Office for Civil Rights issued new HIPAA Privacy Rule Guidance in response to the Supreme Court’s decision in Dobbs v Jackson Women’s Health Organization and state legislation which followed the decision...more
10/21/2022
/ Covered Entities ,
Department of Health and Human Services (HHS) ,
Disclosure ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
HIPAA Privacy Rule ,
New Guidance ,
OCR ,
Patient Privacy Rights ,
PHI ,
Records Request