Employers that sponsor retirement plans continue to have a lot on their plate. With SECURE Act 2.0 requirements now in play, this legislation continues to add more and more to your (already) overflowing plate. However, as is...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 IRS recently issued Notice 2024-02— dubbed the “Grab Bag Notice”— which addresses multiple provisions in SECURE 2.0. The guidance is 81 pages long, comes in the form of frequently asked questions and answers, and speaks...more
The IRS recently issued Notice 2024-2, which provides Q&A guidance on many provisions of the SECURE 2.0 Act, which had left employers and practitioners asking questions. We previously summarized several of the key changes...more
The IRS released long-awaited guidance under the SECURE 2.0 Act on December 20, 2023. Notice 2024-2 (Notice) provides clarification of various provisions, including several optional features that plan sponsors have been...more
Beginning this year, plan sponsors may increase their qualified plan’s mandatory cash-out limit from $5,000 to $7,000. The increase was enacted by SECURE 2.0, and applies to distributions made after December 31, 2023....more
The next installment of our updates on SECURE 2.0 is on another new in-service withdrawal option. SECURE 2.0 allows plan sponsors of defined contribution plans to amend their plans to allow plan participants who are victims...more
Our prior bulletin summarized the multitude of changes applicable to 401(k) and other retirement plans under the recently enacted “SECURE 2.0” law. This bulletin focuses on one of those changes and a potential reason for...more
Federal Bill C-228 (the Bill), new legislation intended to improve the protection of, and to extend the super-priority given to claims relating to, defined benefit pension plans in insolvency proceedings, completed third...more
The April Monthly Minute examines upcoming Form 5500 changes (which particularly impact small plans) and a recent case highlighting the importance of compliance with plan termination procedures....more
New legislation commonly called “SECURE 2.0” was passed by Congress last week and signed into law on Tuesday by President Biden. The new legislation includes almost 100 different changes that are linked to retirement plans. ...more
Earlier this year, the Internal Revenue Service (IRS) issued Notice 2022-23, which extended the deadline to make certain amendments pursuant to the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019,...more
The IRS has extended additional deadlines for required retirement plan amendments, similar to the extensions we discussed last month found here. Notice 2022-45 extends the deadline for amending qualified retirement plans to...more
The IRS on Aug. 3, 2022, issued Notice 2022-33, which extends the deadlines for qualified retirement plans, 403(b) plans and governmental retirement plans (including 457(b) plans) to adopt amendments reflecting certain...more
The IRS has issued a notice extending the deadline for retirement plan sponsors to make certain amendments required by recently passed legislation. Notice 2022-33 extends the deadline for amending qualified retirement plans...more
The IRS has given plan sponsors more time to adopt some – but apparently not all – retirement plan amendments reflecting law changes in the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the...more
Background (Effective elimination of determination letter process) - In Revenue Procedure 2016-37 the IRS eliminated the determination letter process for individually designed plans for all situations except initial plan...more
Late last year, House Ways and Means Committee Chairman Richard E. Neal (D-MA) and Ranking Member Kevin Brady (R-TX) introduced the Securing a Strong Retirement Act of 2020 (SECURE 2.0), a bipartisan legislative proposal that...more
The Internal Revenue Service has announced that, in light of the COVID-19 pandemic, its March 31, 2020, deadline for remedial amendments to section 403(b) plans has been extended to June 30, 2020....more
Pension plans that are not fully funded for PBGC purposes have two parts to their PBGC premium. One part is a flat rate premium of $83 per participant in 2020 ($80 for 2019). The other is a variable rate premium that looks to...more
Newly published Revenue Procedure 2019-19 modifies and supersedes prior IRS guidance regarding the Employee Plans Compliance Resolution System (EPCRS) to allow plan sponsors to self-correct an expanded number of problems that...more
I know a thing or two about the virtues of flat fee billing, have done my legal work on the scale while working for a couple of third party administration (TPA) firms. Plan documents, plan amendments, and plan terminations...more
I didn’t have such a great time at law school because I felt the administration and much of the faculty weren’t honest when it came to the study of law and more importantly, our job opportunities. There was one law professor...more
In Announcement 2017-11, the IRS relaxed standards for hardship distributions and loans from qualified retirement plans for those affected by Hurricane Harvey. This relief applies to employees or former employees and their...more