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On July 18, 2024, the Internal Revenue Service (IRS) issued final regulations updating the required minimum distribution (RMD) rules. The final regulations reflect changes made by the Setting Every Community Up for Retirement...more
The Internal Revenue Service issued interim guidance on employer matching contributions made to retirement plans related to qualified student loan payments (QSLPs) made by employees....more
Seyfarth Synopsis: On August 19, 2024, the IRS issued Notice 2024-63 (the “Notice”) providing guidance for plan sponsors that wish to provide matching contributions based on eligible student loan repayments made by...more
Section 110 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) permits employers maintaining a 401(k), 403(b), governmental 457(b), or SIMPLE IRA plan to make matching contributions based on qualified student loan payments...more
The retirement plan industry has been wrestling with the changes to required minimum distribution (RMD) provisions made by the SECURE Act and SECURE 2.0. One issue in particular has caused considerable confusion....more
The August Monthly Minute highlights new IRS guidance addressing student loan matching programs, HHS’s increases to civil monetary penalties and Form 5330 paper filing updates....more
Since 1984, citation to Chevron v. Natural Resources Defense Council ("Chevron") has meant that courts should defer to an agency's interpretations of an ambiguous statute—as long as the agency's interpretation is...more
The SECURE 2.0 Act of 2022 (“SECURE 2.0”) permits employers to match student loan payments made by employees under 401(k), 403(b), governmental 457(b), or SIMPLE IRA plans in plan years beginning on or after January 1, 2024....more
The IRS recently published its final regulations addressing changes to Tax Code Section 401(a)(9), relating to required minimum distributions (RMDs), under the Setting Every Community Up for Retirement Enhancement Act of 2019...more
On June 20, 2024, the Internal Revenue Service (“IRS”) released Notice 2024-55 (the “Notice”) offering guidance on two (2) new types of distributions exempt from the 10% early withdrawal penalty: emergency personal expense...more
On behalf of the ESOPs, Benefits & Compensation team, we hope your Summer is off to a great start. In the time of family vacations and out-of-office replies, the pace of employee benefits changes—both large and small—remains...more
The IRS has for the third consecutive year offered relief to taxpayers covered by the “10-year rule” for required minimum distributions (RMDs) from inherited IRAs or other defined contribution plans. Let’s look at how this...more
On July 18, 2024, the IRS finalized changes to the regulations governing required minimum distributions (“RMDs”) to reflect changes made by the Setting Every Community Up for Retirement Act of 2019 (“SECURE Act”) and SECURE...more
At long last, the Treasury Department and the Internal Revenue Service (“IRS”) issued final (and new proposed) regulations that address the major changes to Code section 401(a)(9) under the Setting Every Community Up for...more
On July 18th, the Internal Revenue Service released final regulations regarding required minimum distributions (RMDs) from retirement accounts. The final regulations reflect changes to the Internal Revenue Code made by the...more
The SECURE 2.0 Act of 2022 (“SECURE 2.0”) made numerous changes to the complex web that makes up U.S. retirement plan laws. Of interest to S corporations that may be considering an employee stock ownership plan (“ESOP”) is...more
The Internal Revenue Service issued guidance in Notice 2024-55 on applying exceptions to the 10% excise tax under Internal Revenue Code (IRC) Section 72(t) for emergency personal expense distributions and domestic abuse...more
The ERISA Industry Committee (ERIC) is pushing back on the Department of Labor (DOL) ask to require retirement plans to provide what it calls excessive amounts of participant information for its SECURE 2.0-mandated...more
Hard-working Americans spend a lifetime trying to obtain financial stability and to then provide a financial legacy for their families. Often, the strategy to achieve such goals involves the funding of individual retirement...more
On April 16, 2024, the IRS released Notice 2024-35, extending the previously provided temporary relief from certain required minimum distribution (RMD) requirements for beneficiaries under qualified defined contribution plans...more
Of interest to 401(k) plan sponsors and administrators, the IRS recently issued Notice 2024-55, providing guidance on SECURE 2.0’s new exceptions—effective January 1, 2024—to the additional 10% tax on early qualified...more
SECURE 2.0 provided employees better access to liquid assets during a major life crisis. We have previously discussed the domestic abuse victim distribution exemption and the emergency personal expense distribution exemption...more
The Internal Revenue Code generally discourages retirement plan participants from requesting distributions from their retirement plan funds prior to age 59 ½ by imposing an additional 10% tax on those distributions. However,...more
Administering a retirement plan is a complicated task fraught with potential missteps. Fortunately, employers are now able to self-correct most errors and thereby avoid the considerable time and expense of filing an...more
The IRS recently issued guidance in Notice 2024-55 on the application of two new exceptions to the 10% additional tax under Code section 72(t) for early withdrawals from a qualified plan or IRA, which were added by Sections...more