Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
On August 19, 2024, the Internal Revenue Service (“IRS”) issued Notice 2024-63 (the “Notice”) for retirement plan sponsors that provide, or may wish to provide, matching contributions based on qualified student loan payments...more
The IRS has for the third consecutive year offered relief to taxpayers covered by the “10-year rule” for required minimum distributions (RMDs) from inherited IRAs or other defined contribution plans. Let’s look at how this...more
On December 20, 2023, the IRS issued Notice 2024-2, which provides question-and-answer guidance on various aspects of the SECURE 2.0 Act. This post focuses on the ability to make employer contributions (match or nonelective)...more
The IRS issued Notice 2024-2 (Notice), which provides guidance in a question and answer format concerning certain provisions of the SECURE 2.0 Act of 2022 (SECURE 2.0). The following is a brief overview of key provisions in...more
The Internal Revenue Service (IRS) gave plan sponsors an early Christmas gift with the release of new guidance late last year addressing several key provisions contained in SECURE 2.0. A welcome portion of the notice was...more
Congress continues to pass laws that move 403(b) plans ever closer to 401(k) plans, but 403(b) plans remain distinct. Understanding these differences allows you to maintain a compliant plan that best serves the needs of your...more
Seyfarth Synopsis: Under Section 604 of Secure 2.0, sponsors of 401(k), 403(b) and governmental plans may allow employees to designate employer match (including match on student loan repayments) or nonelective contributions...more
Historically, qualified retirement plans have excluded part-time employees from participation. An employer’s ability to do so has now been limited by the Setting Every Community Up for Retirement Enhancement Act (“SECURE...more
New proposed regulations clarify how employers should implement retirement plan eligibility rules for long-term, part-time ("LTPT") employees. While some questions remain, the proposed regulations provide a number of welcome...more
As 2023 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. Part 1 covered health and welfare plan...more
The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more
In efforts to expand access to retirement savings programs for more Americans, the SECURE Act and SECURE 2.0 both included new rules that will require plans to allow long-term part-time (LTPT) employees to make elective...more
The Secure 2.0 Act (Secure 2.0), a sweeping retirement bill included in Division T of the Consolidated Appropriations Act of 2023, was a major bipartisan accomplishment of the 117th Congress. The bill included 82 provisions...more
While most of the country was gearing up for the U.S. Open, retirement plan sponsors and service providers collectively celebrated a big win on August 25 when the IRS delayed the new Roth catch-up rule until January 1, 2026. ...more
A recent announcement from the IRS (IR-2023-62) modifies and clarifies Roth IRA catch-up payment requirements for contributors who are aged 50 or older. IR-2023-62 delayed mandatory Roth IRA catch-up payments for high income...more
On August 25, 2023 the Internal Revenue Service issued Notice 2023-62, which provides a critical 2-year delay in the enforcement of new retirement plan Catch-up Contributions rules passed under the Secure 2.0 Act of 2022....more
One of SECURE 2.0’s interesting provisions was that people who are highly compensated employees (HCEs) will be forced to make the catch-up contributions they want on an after-tax basis. That provision was a revenue generator...more
To the relief of plan sponsors everywhere, the Internal Revenue Service (IRS) recently issued Notice 2023-62, which provides guidance on the requirements of Section 603 of the SECURE Act 2.0 of 2022 relating to catch-up...more
Section 603 of the SECURE 2.0 Act of 2022 (“Section 603”) implements changes to catch-up contributions and is applicable to employers who maintain a 401(k), 403(b), or 457(b) plan with participants who are age 50 and older...more
IRS guidance issued last week delays the implementation of mandatory Roth catch-up contributions. As outlined in our blog post earlier this year, SECURE 2.0 amended the catch-up contribution provisions of the Code....more
On August 25, 2023, the IRS issued IRS Notice 2023-62, providing much needed relief for employers who have been struggling to implement Section 603 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”), which requires high income...more
The Internal Revenue Service (“IRS”) provided welcome relief for administrators of plans offering catch-up contributions. Notice 2023-62, issued on August 25, essentially delays the effective date of a provision under the...more
Section 603 of the SECURE 2.0 Act of 2022 (SECURE 2.0) requires that catch-up contributions for individuals whose wages exceed $145,000 are subject to mandatory Roth tax treatment effective as of January 1, 2024. Due to the...more
The IRS issued guidance on Friday, August 25, 2023, under Section 603 of the SECURE 2.0 Act of 2022, which requires age-based catch-up contributions by high-paid employees to a 401(k), 403(b), or governmental 457(b) plan to...more