PODCAST: Williams Mullen's Benefits Companion - Big Changes to Catch-Up Contributions in 2025
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Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more
On January 10, 2025, the Treasury Department and the Internal Revenue Service issued Proposed Regulations on the automatic enrollment requirements introduced by SECURE 2.0. The Proposed Regulations incorporate and expand...more
New guidance facilitates the implementation and operation of two important SECURE 2.0 features: mandatory Roth catch-up contribution rules for high-income participants, and the optional "super" catch-up contributions...more
The Internal Revenue Service (IRS) issued proposed regulations providing guidance on how to interpret and implement changes to "catch-up" contributions made by the SECURE 2.0 Act of 2022 (SECURE 2.0). The regulations mainly...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
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
New proposed regulations issued by The Department of Treasury and IRS provide guidance on the provisions related to catch-up contributions that were included under SECURE 2.0 Act of 2022 (“SECURE 2.0”)....more
On January 10, 2025, the Department of the Treasury and the Internal Revenue Service issued proposed regulations related to two new catch-up contribution provisions under the SECURE 2.0 Act of 2022 (SECURE 2.0): (1) the...more
SECURE 2.0 was enacted on December 29, 2022. Among its provisions is a requirement that “new” 401(k) plans and private sector 403(b) plans must automatically enroll their eligible employees, but not until the first plan year...more
The Internal Revenue Service (IRS) regularly requires retirement plans to incorporate new laws and regulations. To ensure that pre-approved retirement plans incorporate these required legal and regulatory updates, the IRS...more
In the past week, devastating wildfires in Los Angeles, California, have caused unprecedented destruction across the region, leading to loss of life and displacing tens of thousands. While still ongoing, the fires already...more
One of the option of SECURE 2.0 is allowing employers to offer partricipants the right to Roth Employer contributions where they can pay the taxes upfront, and get tax free treatment on employer contributions....more
On January 10, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations regarding the provisions of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) that relate to...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
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
In the wake of the horrific wildfires in Los Angeles (which are ongoing as of today), employees based in the Los Angeles area may have questions about available support from employer-sponsored 401(k) plan accounts and other...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
In Notice 2024-73, the Internal Revenue Service (“IRS”) issued guidance on the application of certain non-discrimination rules to long-term, part-time employees in Internal Revenue Code (“Code”) Section 403(b) plans subject...more
Among the provisions of SECURE 2.0 (effective December 29, 2022) welcomed by plan sponsors were the additions to the Internal Revenue Code that allow qualified plans to refrain from trying to recoup an “inadvertent benefit...more
Employers now have a new benefit option in their toolbelt: The Qualified Student Loan Payment (QSLP) match. But is it worth implementing? Before diving into the specific legal requirements for a QSLP match program, this...more
All qualified retirement plans are subject to a myriad of requirements of the Employee Retirement Income Security Act of 1974, as amended (ERISA). The United States Department of Labor (DOL) is charged with enforcing the...more
If the U.S. Department of Labor’s Notice of Proposed Information Collection Request, issued on April 15, 2024, becomes final, fiduciary retirement plan committees may be asked to evaluate the important question of whether the...more
Pension-Linked Emergency Savings Accounts (“PLESAs”) are a special retirement plan feature created under SECURE ACT 2.0. PLESAs were first permitted to be made available to participants as of January 1, 2024. PLESAs, which...more
We are often asked about the permissibility of excluding certain categories of employees from participating in an employer’s tax-qualified retirement plan. This post provides a high-level summary of what is and is not...more