On December 20, 2019, Congress enacted the SECURE Act as part of the Further Consolidated Appropriations Act of 2020 (together, the “Act”). The Act includes both required and discretionary changes for employer-sponsored...more
To address data privacy considerations, employers using the same IRS forms used to satisfy Federal Reporting should consider redacting information for individuals residing outside the Adopting Jurisdiction for which the...more
March 31, 2020 is the deadline for retroactively correcting most 403(b) plan document defects that occurred on or after January 1, 2010. These defects can be corrected by amending an individually-designed 403(b) plan or by...more
The Internal Revenue Service has recently issued final regulations easing requirements for hardship distributions from 401(k) and 403(b) plans. The final regulations reflect a number of statutory changes, including those made...more
The Departments of Labor, Health and Human Services and Treasury recently issued joint final regulations expanding the availability of health reimbursement arrangements (“HRAs”) by introducing two new types of HRAs –...more
On July 17, 2019, the Treasury Department and the IRS issued Notice 2019-45 to expand the types of preventive care services and benefits that can be provided to individuals under high deductible health plans (“HDHPs”) before...more
As mentioned in our January 2018 and March 2018 Client Advisories, the Tax Cuts and Jobs Act (the “Act”), provides a temporary corporate federal tax credit, ranging from 12.5 percent to 25 percent, that may be claimed by...more
This Advisory supplements our previous advisories dated January 2018, December 2016, December 2015 (as supplemented in January 2016), October 2014, October 2013, November 2012, November 2011, and October 2010, addressing...more
12/6/2018
/ Affordable Care Act ,
Anti-Assignment Clauses ,
Association Health Plans ,
Cadillac Tax ,
Centers for Medicare & Medicaid Services (CMS) ,
Cost-Sharing ,
Employee Retirement Income Security Act (ERISA) ,
Form 1094 ,
Form 1095 ,
Healthcare Reform ,
Individual Mandate ,
IRS ,
Popular
As we approach the end of 2018, qualified retirement plan sponsors should consider reviewing the various changes brought on by recent legislation, regulations and agency guidance to determine whether any plan amendments or...more
As employers look for creative ways to help employees manage their student loan debt, the IRS recently ruled that employer nonelective contributions to a 401(k) plan for employees who make student loan repayments would not...more
IRC §162(m) limits a publicly held corporation’s ability to take a tax deduction for compensation paid to covered employees in excess of $1 million. As mentioned in our January 2018 Client Advisory, the Tax Cuts and Jobs Act...more
As mentioned in our January 2018 Client Advisory, the Tax Cuts and Jobs Act (the “Act”), signed into law at the end of 2017, contains significant changes affecting the tax treatment of certain fringe benefits and executive...more
The IRS recently released guidance providing that taxpayers may, for 2018, treat $6,900 as the maximum deductible health savings account (“HSA”) contribution for family coverage under a high deductible health plan. This...more
As mentioned in our January 2018 Client Advisory, the Tax Cuts and Jobs Act (the “Act”), signed into law at the end of 2017, contains a temporary corporate federal tax credit, ranging from 12.5 percent to 25 percent, that may...more
The Bipartisan Budget Act of 2018 (“Act”) was signed into law on February 9, 2018. It includes certain provisions impacting employee benefits, 401(k) plans in particular. The following is a brief description of some notable...more
As we communicated in our previous advisory, the U.S. Department of Labor has issued new Disability Claims Procedures rules. The original effective date of these rules was extended with the result that the new rules are now...more
Cadillac Tax -
The budget deal recently struck by Democrats and Republicans further delays, until 2022, the Cadillac Tax. As you recall, the tax, designed to impose a 40 percent tax on the cost of employer-sponsored...more
At the end of 2017, President Trump signed into law The Tax Cuts and Jobs Act (the “Act”) that includes significant changes in the employee benefits area, most of which became effective on January 1, 2018. The following is a...more
President Signs Bill Granting Hurricane Disaster Relief -
In the wake of the devastation caused by Hurricanes Harvey, Irma and Maria, President Trump recently signed the Disaster Tax Relief and Airport and Airway Extension...more
Effective January 1, 2017, except for the last batch of Cycle A filers who were permitted to submit determination letters by January 31, 2017 (i.e., filers with an EIN ending in 1 or 6), the IRS will no longer accept...more
The U.S. Department of Labor has issued new regulations affecting how disability claims are handled under ERISA plans that provide disability benefits or base receipt of benefits on the existence of a disability. While most...more
This Advisory supplements our previous advisories dated December 2015 (as supplemented in January 2016), October 2014, October 2013, November 2012, November 2011, and October 2010, addressing the requirements of the...more
12/7/2016
/ Affordable Care Act ,
Anti-Retaliation Provisions ,
Cost-of-Living Adjustment (COLA) ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
IRS ,
Non-Discrimination Rules ,
Popular ,
Reporting Requirements ,
Section 1557 ,
Trump Administration
Pursuant to additional federal guidance issued at the end of 2015, this Advisory supplements our previous advisory regarding important Affordable Care Act (“ACA”) mandates effective in 2016. As explained below, the ACA...more
Unlike most other years since the Affordable Care Act (“ACA”) was passed, there are relatively few new requirements employers need to implement in connection with their health plans subject to the ACA. This Advisory...more
Unless you’ve been living under a rock, you probably are well aware that on June 26, 2015, the U.S. Supreme Court ruled that same sex couples have a constitutional right to marry and have their marriages recognized across the...more
7/8/2015
/ Benefit Plan Sponsors ,
Discrimination ,
DOMA ,
Employee Benefits ,
Employee Rights ,
Employment Policies ,
Family and Medical Leave Act (FMLA) ,
LGBTQ ,
Marital Status ,
Marriage Equality ,
Obergefell v. Hodges ,
Same-Sex Marriage ,
SCOTUS ,
Spouses ,
US v Windsor