THE ACCIDENTAL ENTREPRENEUR PART IV
Proposed Treasury regulations relating to catch-up contributions were issued in January of 2025 that include guidance for the mandatory Roth catch-up requirement, which was first provided under section 603 of Division T of...more
The IRS issued Proposed Regulations last month which provide helpful clarity for employers on how to implement and comply with two new SECURE 2.0 provisions relating to catch-up contributions....more
Background - Many defined contribution plans are designed to permit participants to take advantage of an increased employee contribution limit starting the year they turn 50....more
If you are 73 or older, remember to take your Required Minimum Distributions from any retirement plan or IRA you may have. As discussed in prior blog posts, Required Minimum Distributions (“RMDs”) are taxable amounts that...more
With 2024 drawing to a close, employers should review any actions needed before year-end with respect to their benefit plans, as well as some upcoming deadlines that may require advance planning. As the adage attributed to...more
IRS reminds employers that implementing certain optional retirement plan provisions of SECURE 2.0 affect Form W‑2 and Form 1099‑R reporting starting in 2023 - The IRS recently issued Fact Sheet 2024‑18 to highlight how...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 Internal Revenue Service and U.S. Department of Labor recently issued guidance on various aspects of the Consolidated Appropriations Act of 2023, commonly referred to as SECURE 2.0. Below is a summary of key provisions...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
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
As many surely recall, the SECURE 2.0 Act of 2022 included nearly 100 provisions affecting retirement plans. While a number of the new rules became effective immediately, another portion is scheduled to take effect in 2024....more
While amendments for the following changes under the SECURE Act and SECURE 2.0 Act are not yet required, retirement plan sponsors (especially 401(k) and 403(b) plan sponsors) need to be aware of the following operational...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
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
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
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
On August 25, 2023, the IRS announced a two-year delay for the Roth catch-up contribution requirement for employees making $145,000 or more in the prior calendar year that would have applied in 2024. The Roth catch-up...more
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
On August 25, 2023, the IRS issued Notice 2023-62 to address certain industry concerns over implementation of Section 603 of the SECURE 2.0 Act. Section 603 relevantly provides that, beginning in 2024, participants eligible...more
On August 25, 2023, the IRS issued guidance delaying until January 1, 2026 the SECURE 2.0 requirement that any age 50 catch-up contributions by an employee with prior-year compensation over $145,000 be made on a Roth basis,...more
With a multitude of questions surrounding implementation and administration, late on a summer Friday afternoon, the IRS issued Notice 2023-62 (Notice), providing Plan Sponsors with a transition period until 2026 to implement...more
SECURE 2.0 brought significant changes to retirement planning and distributions, including updating the Required Minimum Distribution (RMD) requirements. As background, RMDs are the minimum amounts that individuals who...more
In this series of articles, we explore the implications of SECURE 2.0’s changes to catch-up contributions and how employers should respond. The SECURE 2.0 Act indicates that any plan that permits catch-up contributions...more