News & Analysis as of

Internal Revenue Service Plan Administrators

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Shipman & Goodwin LLP

Plan Forfeiture Litigation: A Trend to Watch

Shipman & Goodwin LLP on

The most recent wave of ERISA litigation is focused on the use of plan forfeitures in 401(k) plans, with the newest case, Armenta v. WillScot Mobile Mini Holdings Corp. being filed just last week. Although, for years, many...more

McDermott Will & Emery

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

McDermott Will & Emery on

Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

Dickinson Wright

Both Employers and Participants Benefit from New IRS Guidance on Correcting Inadvertent Benefit Overpayments

Dickinson Wright on

Retirement plan administration mistakes require difficult conversations with participants, especially when the mistake involves an overpayment.  Changes in the law, specifically, SECURE 2.0 and IRS Notice 2024-77, give plan...more

Seyfarth Shaw LLP

Want to Put More Away in Your 401(k)? Qualified Plan Limits Generally Increase in 2024

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS just announced the 2024 annual limits that will apply to tax-qualified retirement plans. For a third year in a row, the IRS increased the annual limits, allowing participants to save even more in...more

Bricker Graydon LLP

To Roth or Not to Roth - That is No Longer the Question for Some Catch-Up Eligible Individuals

Bricker Graydon LLP on

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

Williams Mullen

Treasury Issues Anticipated Relief for New Catch-up Contribution Rule

Williams Mullen on

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

Faegre Drinker Biddle & Reath LLP

Use of Forfeitures in Qualified Retirement Plans

On February 27, 2023, the IRS and the Department of Treasury published proposed regulations regarding the use of forfeitures in qualified retirement plans. If finalized, the proposed rule will be effective for plan years...more

Pullman & Comley - Labor, Employment and...

Secure Act 2.0 Creates Greater Opportunities for Self-Correction of Retirement Plans

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

Faegre Drinker Biddle & Reath LLP

Final Changes Announced to Forms 5500 and 5500-SF

The Department of Labor (DOL) announced that it has finalized, together with the Internal Revenue Service (IRS) and Pension Benefit Guarantee Corporation (PBGC), the third and final round of revisions to the Form 5500 Annual...more

Harris Beach Murtha PLLC

IRS Issues Proposed Regulations Governing the Use of Forfeitures in Qualified Retirement Plans

The IRS recently issued Proposed Regulations that clarify and update existing rules governing how and when forfeitures must be used in qualified defined contribution (e.g., 401(k)) and defined benefit retirement plans. ...more

Groom Law Group, Chartered

IRS Proposed Regulation Addresses Rules Relating to Plan Forfeitures

Historically, the topic of forfeitures has raised many questions for qualified plan administrators- specifically, how and when they can be used.  But there has been little formal guidance from the Department of Treasury and...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Annual Notice of Discretionary Match in ‘Pre-Approved’ 401(k) Plans May Be Required Soon!

Employers that provide 401(k) plans on documents that have been “pre-approved” by the Internal Revenue Service (IRS) beware: there is yet another annual notice requirement that may need to be added to your compliance list!...more

Foley & Lardner LLP

401(k) Compliance Check #12: Don’t Borrow Trouble – Correcting Retirement Plan Loan Errors

Foley & Lardner LLP on

In last month’s 401(k) Compliance Check, we discussed the importance of developing (and maintaining) best practices for handling beneficiary designations. This month, we discuss one of the most common problems faced by 401(k)...more

Foley & Lardner LLP

401(k) Compliance Check #10: Magic Words – Best Practices for 401(k) Plan SPDs

Foley & Lardner LLP on

To help employers properly administer their 401(k) plans, in 2022, Foley & Lardner LLP is authoring a series of monthly “401(k) Compliance Check” newsletters. This article includes some tips for drafting a best-in- class...more

Laner Muchin, Ltd.

Plan Administrators of Retirement Plans Need to Prepare for New IRS Pre-Examination Compliance Pilot Program

Laner Muchin, Ltd. on

On June 3, 2022, the Internal Revenue Service (IRS) announced a new pilot program aimed at qualified retirement plan compliance. Pursuant to the program, the IRS will issue a letter to the plan administrator which provides a...more

Proskauer - Employee Benefits & Executive...

No Presence? No Problem: Temporary Relief for Witnessing Spousal Consent Further Extended Through Year-End

Perhaps channeling the old adage of “if it ain’t broke, don’t fix it,” the IRS recently released Notice 2022-27 extending through December 31, 2022 its temporary relief from the requirement that spousal consent for plan...more

Snell & Wilmer

Can’t Touch This: IRS Extends Physical Presence Relief for Remote Notarization

Snell & Wilmer on

On December 23, 2020, the IRS issued Notice 2021-03, which extends relief from the “physical presence” requirement applicable to signatures that must be witnessed by a plan representative or notary public. By way of...more

Holland & Hart - The Benefits Dial

I Would Walk 500 Miles … But Thankfully I Don’t Have To Since the IRS Will Still Permit E-Signature

The Covid-19 pandemic has created numerous challenges for retirement plan administrators. One such challenge is how to comply with the requirement to obtain a participant’s written signature to get a distribution from a...more

Pullman & Comley - Labor, Employment and...

A Cautionary Tale for Retirement Plan Sponsors’ Avoidable Late Filing Penalties

Do you remember the scene in the Wizard of Oz when Dorothy, the Scarecrow and Tin Man were walking into the forest chanting “lions and tigers and bears, oh my”?  I could not help but mutter “oh my” under my breath when I...more

Foley & Lardner LLP

Time to Update Your Retirement Plan’s Tax Notice

Foley & Lardner LLP on

Internal Revenue Code Section 402(f) requires plan administrators of certain retirement plans to provide a tax notice to payees that describes their rollover rights. The Internal Revenue Service (IRS) historically has...more

Proskauer - Employee Benefits & Executive...

Side by Side Comparison: Electronic Disclosure Rules for Pension & Welfare Plans

The DOL recently provided retirement plans with a new method to comply electronically with certain participant disclosure and notice requirements. See our blog post outlining the new DOL rule. This new method adds to the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

IRS Issues Additional CARES Act Guidance for Retirement Plan Administrators and Qualified Individuals

The Internal Revenue Service (IRS) recently released two notices that provide additional guidance for retirement plan administrators and qualified individuals about the special distribution, plan loan, and required minimum...more

Williams Mullen

IRS and DOL Grant Plan Administrators Some Relief During Pandemic

Williams Mullen on

The Internal Revenue Service (IRS) and the Department of Labor (DOL) jointly offered extensions and other relief to employee benefit plan administrators that may be struggling to meet various filing, notice, disclosure and...more

Ruder Ware

IRS Provides More Retirement Plan and IRA Relief

Ruder Ware on

Yesterday, the IRS issued additional guidance regarding two hot topics over the last six months: the waiver of the 2020 required minimum distributions (RMDs) from retirement plans and IRAs, and the change in the required...more

Proskauer - Employee Benefits & Executive...

DOL/Treasury COVID-19 Relief Includes Long Extension of Participant Deadlines and Rule of Reasonableness for Plan Administration

On April 29, 2020, the U.S. Departments of Labor (Employee Benefits Security Administration, “EBSA”) and Treasury (IRS) published a final regulation, and EBSA issued a package of guidance and relief, for employee benefit...more

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