News & Analysis as of

Employee Contributions SECURE Act 403(b) Plans

Bricker Graydon LLP

Act 3: To Roth or Not to Roth - That Is No Longer the Question for Some Catch-Up Eligible Individuals

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The IRS this past Friday issued proposed regulations regarding mandatory Roth catch-up contributions. SECURE 2.0 amended the catch-up contribution provisions of the Code....more

Tarter Krinsky & Drogin LLP

Year-End and 2025 Action Items for Health Funds and 401(k) Plans

Group health plans, including insured and self-insured plans, are prohibited from entering contracts that contain a gag clause. These provisions prohibit group health plans from entering agreements with a healthcare...more

The Wagner Law Group

Prepare for Upcoming Changes to Retirement Plans for 2025

The Wagner Law Group on

The SECURE 2.0 Act of 2022 (the “SECURE 2.0”) made significant changes to retirement plans and how they operate. Many of the changes have already been implemented by service providers, but some sponsors will need to plan for...more

Faegre Drinker Biddle & Reath LLP

Roth Employer Contributions

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

Holland & Knight LLP

IRS Issues Notice 2024-2 Outlining Guidance on SECURE 2.0 Provisions

Holland & Knight LLP on

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

Bricker Graydon LLP

The Gift That Keeps on Giving: New IRS Guidance on Roth Employer Contributions

Bricker Graydon LLP on

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

Bricker Graydon LLP

403(b) Plans - Not Your Average Salary Deferral Plan

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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 Shaw LLP

“SECURE-ing” the Answers to Outstanding Questions on the Rothification of Employer Contributions

Seyfarth Shaw LLP on

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

Davis Wright Tremaine LLP

New IRS Guidance on Long-Term, Part-Time Employee Retirement Plan Participation

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

Bricker Graydon LLP

Have You Been Counting Those Long-Term Part-Time Employee Hours? Initial Plan Year Eligibility is Fast Approaching.

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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

Kohrman Jackson & Krantz LLP

Treasury Provides Temporary Relief from 401(k) Catch-up Contributions Rollback - Update

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

Foley & Lardner LLP

Diving Into SECURE 2.0: New DOL Lost and Found, Updates to EPCRS, and Delayed Implementation of Roth Catch-up Requirement

Foley & Lardner LLP on

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

Foley & Lardner LLP

And The Crowd Goes Wild: IRS Delays SECURE 2.0 Roth Catch-Up Rule Until 2026

Foley & Lardner LLP on

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

Allen Barron, Inc.

IRS Modifies and Clarifies Roth IRA Plan Catch-Up Payment Requirements

Allen Barron, Inc. on

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

Best Best & Krieger LLP

New Guidance - Secure 2.0 Roth Treatment of Catch-up Contributions

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

Epstein Becker & Green

SECURE 2.0: Roth Catch-Up Contribution Delay

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

Ballard Spahr LLP

IRS Delays Enforcement of Roth Catch-Up Contribution Requirement for Two Years

Ballard Spahr LLP on

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

Stinson LLP

IRS Announces Delay of Implementation of SECURE 2.0 Act’s Roth Catch-Up Contribution Provision for Two Years

Stinson LLP on

As signed into law, Section 603 of the SECURE 2.0 Act of 2022 (SECURE 2.0) required that effective as of January 1, 2024, participants in 401(k) plans, 403(b) plans, or governmental 457(b) plans, who were age 50 or older and...more

Eversheds Sutherland (US) LLP

More time to catch up: IRS announces two year delay of Roth catch-up requirement

The IRS has announced a two-year “administrative transition period” for plan sponsors to implement the SECURE 2.0 Act provision requiring higher-income employees to make retirement plan catch-up contributions as Roth...more

Pullman & Comley - Labor, Employment and...

Retirement Plans: Will January 1, 2024 Effective Date for Age 50 Catch-Up Contribution Changes Be Delayed?

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

Cozen O'Connor

SECURE ACT 2.0: Wow, What a Difference an Act Makes!

Cozen O'Connor on

The Consolidated Appropriations Act of 2023 was signed into law on December 29, 2022, and has ushered in one of the most significant pieces of retirement plan legislation in recent memory. SECURE Act 2.0 (SECURE 2.0) contains...more

McDermott Will & Emery

[Webinar] SECURE 2.0 Takes Second Bite at Retirement Security - January 25th, 12:00 pm - 1:00 pm CST

McDermott Will & Emery on

Join partners from McDermott’s Employee Benefits team as they discuss the impact of the recently passed SECURE 2.0 Act of 2022. With over 90 changes to retirement plans and individual retirement accounts (IRAs), this webinar...more

Warner Norcross + Judd

SECURE 2.0 is Finally Here! Warner Analysis Part 1

Warner Norcross + Judd on

The long-awaited sequel to the SECURE Act enacted in 2019 is finally here. On December 29, 2022, President Joe Biden signed the Consolidated Appropriations Act of 2023, which includes the SECURE 2.0 Act of 2022 (“SECURE 2.0”...more

Jackson Lewis P.C.

More Roth, More Catch-Up, and Catch-Up As Roth, Part 1 of the JL SECURE 2.0 Series

Jackson Lewis P.C. on

The SECURE 2.0 Act of 2022 (SECURE 2.0) contains several provisions that allow the federal government to have its cake (more tax dollars) and eat it too (more retirement savings, easing Social Security challenges). With...more

Houston Harbaugh, P.C.

SECURE 2.0 Act of 2022 Makes Sweeping Retirement Plan Changes

The 2022 holiday season brought a long-awaited gift from Congress; the retirement plan bill known as “SECURE 2.0” (successor to 2019’s Setting Every Community Up for Retirement Enhancement Act, the original “SECURE Act”) was...more

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