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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
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
Under current law, most 401(k) plans permit catch-up contributions that are equally available to all participants who are age fifty or over. Starting in 2025, the SECURE 2.0 Act allows eligible participants who are ages...more
Our Employee Benefits & Executive Compensation Group reminds plan sponsors to get ready for 2024 IRS year-end amendments and offers year-end action items....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 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
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
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
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
As you probably already know, qualified retirement plans are permitted, but are not required, to allow participants who are age 50 or older to make additional elective deferrals (including designated Roth contributions),...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
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
The President signed the Consolidated Appropriations Act, which included SECURE Act 2.0, on December 29, 2022. SECURE Act 2.0 has over 90 provisions, some major and some minor; some mandatory and some optional; some...more
Warner’s Employee Benefits Practice Group is pleased to present a webinar series on significant new retirement plan legislation, the SECURE Act 2.0. While we expect implementing the new law to take several years, some...more
The SECURE 2.0 Act of 2022 (“SECURE 2.0”) was enacted on December 29, 2022, as Division T of the Consolidated Appropriations Act, 2023, the U.S. federal government’s spending bill for fiscal year 2023. SECURE 2.0 builds upon...more
Following the initial flurry of publications summarizing the retirement plan enhancements under the SECURE 2.0 Act of 2022 (“SECURE 2.0”), this post takes a deeper dive into one of those enhancements: the optional...more