THE ACCIDENTAL ENTREPRENEUR PART IV
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
Starting in 2026, Highly Compensated Employees will have to make their Catch Up Contributions as after tax Roth deferrals. The Internal Revenue Service issued regulations to that effect, after the SECURE 2.0’s required...more
The Internal Revenue Service has been busy. On Friday, January 10, 2025, the IRS issued several notices of proposed rulemaking impacting qualified retirement plans. One set of proposed rules adds to the SECURE 2.0 requirement...more
Last year, the IRS issued its long-anticipated final (and newly proposed) regulations to address SECURE 1.0 and 2.0 Act changes to the required minimum distribution (“RMD”) rules (Code section 401(a)(9)). The 2024 proposed...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
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
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 Friday, Aug. 25, 2023, the IRS announced a two-year reprieve for employers on the implementation of SECURE 2.0's requirement that catch-up contributions made by higher-income participants be designated as after-tax Roth...more
The SECURE 2.0 Act of 2022 (“SECURE 2.0”), enacted on December 29, 2022, as Division T of the Consolidated Appropriations Act, 2023 (Public Law No. 117-328), builds upon many changes made earlier by the Setting Every...more
The SECURE Act 2.0 permits plan sponsors to give participants the option of receiving employer contributions on a Roth basis. This provision is effective on the date of enactment, December 29, 2022. However, the...more
SECURE 2.0 Act of 2022 (the “Act”) was signed into law by President Biden on December 29, 2022 (the date of enactment), as part of the larger government funding bill. The Act makes numerous changes affecting retirement plans....more