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Spence v. American Airlines: A Texas Court’s View of the Duty of Loyalty under ERISA

Since we last discussed environmental, social, and corporate governance (“ESG”) developments in the context of ERISA retirement plans, ESG litigation has taken a rather unexpected turn. Although the plan lineup in Spence v....more

Student Loans and Code Section 127 Educational Assistance Programs: A Reminder from the IRS, FAQs, and a Sample Plan Document

On August 28, the IRS issued IR-2024-227, reminding employers of the following key aspects of educational assistance programs under Internal Revenue Code Section 127: -They can be used to help reimburse the costs of or...more

RxDC Reporting in Light of June 1, 2024 Deadline and Recent PBM Litigation

Under the Consolidated Appropriations Act of 2021 (“CAA”), employer-sponsored group health plans, including medical-only plans, must submit information about their prescription drugs and health care spending. This submission...more

Use of Retirement Plan Forfeitures: The IRS Proposed Regulations, Recent Litigation, and the DOL’s Position

In five recently filed class action lawsuits, 401(k) plan participants allege that plan fiduciaries violated ERISA by using plan forfeitures to offset employer contributions instead of paying plan expenses. The use of...more

How to Comply with the Health FSA Debit Card Claims Substantiation Rules

The IRS’s recent Chief Counsel Advice Memorandum 202317020 (the “Memo”) brings into focus the importance of compliance with the debit card claims substantiation requirements for medical care expenses reimbursed or paid for...more

Establishing Practices and Procedures to Support Retirement Plan Self-Correction

The opportunity to self-correct mistakes in maintaining a retirement plan has been dramatically expanded by the SECURE 2.0 Act of 2022 (“SECURE 2.0”); see our February 10 blog post for details. However, IRS interim guidance...more

Pension-Linked Emergency Savings Accounts: Something Old, Something New, Something Borrowed, Something Forthcoming

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

When Cash is not King: Holiday Gifts as “De Minimis” Fringe Benefits

To celebrate the holiday season, this post highlights the tax consequences of employer-sponsored holiday perks such as gift cards, turkeys, hams and gift baskets. Under the current tax rules, employers may give infrequent low...more

Amending Your Retirement Plans this Year for SECURE Act and CARES Act Changes

Last month, the IRS extended the deadline for retirement plan sponsors to adopt amendments necessary to comply with the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”) and the Bipartisan...more

2025 Is the New 2022: IRS Extends Deadline to Adopt SECURE Act Amendments and CARES ACT Waiver of 2020 RMDs Amendment

The extended deadline for adopting these amendments is December 31, 2025, for qualified non-governmental retirement plans, including 401(k) plans, money purchase pension plans, and defined benefit plans, and for 403(b) plans...more

Deciphering First Circuit’s Thirty-page Primer on NQTL Analysis and ERISA Information Requests

The widely publicized 2022 Report to Congress regarding the Mental Health Parity and Addiction Equity Act (“Parity Act”) forewarned greater enforcement efforts by the Department of Labor and highlighted suspected deficiencies...more

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