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IRS Issues Guidance on Employer Matching Contributions for Student Loan Repayments

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) permits employers to match student loan payments made by employees under 401(k), 403(b), governmental 457(b), or SIMPLE IRA plans in plan years beginning on or after January 1, 2024....more

IRS Provides Guidance on Emergency Personal Expense and Domestic Abuse Victim Distributions Under SECURE 2.0

As discussed in our prior alert, the SECURE 2.0 Act of 2022 (“SECURE 2.0”) added new exceptions to the 10% additional tax for emergency personal expense distributions and domestic abuse victim distributions. These new...more

IRS Releases SECURE 2.0 Guidance; Extends Amendment Deadlines

On December 20, 2023, the Internal Revenue Service (“IRS”) issued Notice 2024-2, which provides guidance on some important provisions of the SECURE 2.0 Act of 2022 (“SECURE 2.0”). Notice 2024-2, is not comprehensive guidance...more

2024 IRS Retirement Benefit Plan Limits

The IRS has announced inflation-adjusted limits for retirement plans in Notice 2023-75. ...more

IRS Delays SECURE 2.0 Roth Catch-Up Requirement

Among the most challenging components of the SECURE 2.0 Act of 2022 (SECURE 2.0) for plan sponsors is a requirement that any catch-up contributions for high wage earners can only be made on a Roth (after-tax) basis beginning...more

Federal District Court Narrows Interpretation of Fiduciary Rollover Advice

On February 13, 2023, a federal district court in the Middle District of Florida invalidated the Department of Labor’s (“DOL”) policy as to when advice provided by a financial institution or financial professional (“adviser”)...more

SECURE 2.0 Act of 2022, as enacted Summary of Key Provisions

On December 29, 2022, President Biden signed the Secure 2.0 Act of 2022 (the “Secure 2.0 Act”) into law. The Secure Act 2.0 builds off of the Secure Act, the last major retirement plan legislation enacted at the end of 2019,...more

Senate Proposes Secure 2.0 Act

On December 19, 2022, the Senate Appropriations Committee released the 2023 Consolidated Appropriations Act (“Act”), which includes retirement legislation called the “Secure 2.0 Act.” This proposed bill is very similar to...more

IRS Extends Determination Letter Program to 403(b) Plans

The IRS has issued guidance that for the first time permits companies to apply for determination letters for individually-designed 403(b) Plans. Under the new guidance, determination letters will be available for 403(b) plans...more

IRS Extends CARES and CAA Amendment Deadlines

As discussed in our prior blog post, the IRS previously extended the deadline to adopt most plan amendments relating to the Setting Every Community Up for Retirement Act of 2019 (“Secure Act”), the Bipartisan American Miners...more

Secure Act 2.0 – Summary of Key Provisions

The House and Senate are moving forward on several versions of legislation, which are collectively known as the “Secure Act 2.0” because they would build off of the Secure Act, the last major retirement plan legislation...more

Regulations Proposed on SECURE Act RMD Changes

The IRS released proposed regulations today that implement certain SECURE Act changes to the rules governing required minimum distributions (“RMDs”) from qualified retirement plans, 403(b) plans, IRAs, and certain other...more

Supreme Court Affirms Fiduciaries’ Responsibility for Each Investment Option

The Supreme Court today issued a succinct, unanimous opinion in Hughes v. Northwestern University. The Court affirmed that fiduciaries of retirement plans (including university 403(b) plans like Northwestern’s as well as the...more

DOL Clarifies Timing of Lifetime Income Disclosures in Benefit Statements

Last year the Department of Labor (DOL) issued an interim final rule regarding the SECURE Act’s lifetime income disclosures, which require benefit statements to express a participant’s account balance as a single life annuity...more

IRS Allows for Remote Notarizations for Retirement Plan Withdrawals

Congress acted swiftly to allow participants greater access to their retirement plan funds through special withdrawal and loan provisions in recognition of the financial impacts of the COVID-19 pandemic. See our blog post on...more

CARES Act - Provisions Applicable to Tax-Qualified Retirement Plans

Emergency Withdrawals. Participants in defined contribution plans (profit sharing, 401(k), and 403(b) plans) could access their retirement savings now if plans are amended to allow coronavirus-related withdrawals....more

Changes to Minimum Distribution Rules

The Secure Act is the most significant legislation affecting qualified retirement plans in more than a decade. (See our prior post summarizing key changes.) Changes to the minimum distribution rules are among the most...more

Congress Passes Secure Act with Significant Changes to Retirement Plans

The Setting Every Community Up for Retirement Act of 2019, or "Secure Act", has been passed by Congress as part of a large government funding bill. Upon being signed into law by the President, the Secure Act will be the most...more

IRS Issues Rules for Correcting 403(b) Plan Document Defects

Nonprofit or governmental employers that sponsor 403(b) plans generally have until March 31, 2020, to correct any defects in their 403(b) plan documents by adopting a pre-approved plan document or by amending their...more

IRS Updates VCP User Fees

The IRS has revised its user fees for the Voluntary Correction Program (VCP) effective for submissions made on or after January 2, 2018. VCP is an IRS program that allows plan sponsors to correct failures involving a...more

2018 Benefit Limits

Retirement Plan Limits - The IRS updated very few of the retirement plan limits effective for the plan year that begins on or after January 1, 2018. Social Security Tax and Wage Base - For calendar year 2018, the...more

IRS Allows Easier Access to Retirement Funds for Hurricane Harvey Victims

The IRS issued an announcement that may allow participants and beneficiaries of 401(k) plans or 403(b) plans that have been affected by Hurricane Harvey easier access to their retirement funds until January 31,...more

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