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SECURE Act 2.0: Hold My Beer

Seyfarth Synopsis: The SECURE Act, passed just before the onset of the COVID-19 pandemic at the end of 2019 (“SECURE 1.0”), significantly altered the retirement plan landscape. For a reminder on how the SECURE Act changed the...more

SECURE 2.0: Here We Go Again

Seyfarth Synopsis: The SECURE Act, passed just before the onset of the COVID-19 pandemic at the end of 2019, significantly altered the retirement plan landscape. For a reminder on how the SECURE Act changed the retirement...more

IRS Issues Highly Anticipated Update to Qualified Plan Correction Procedures

On July 16, 2021, the IRS issued Revenue Procedure 2021-30, updating its Employee Plans Compliance Resolution System (“EPCRS”), which permits retirement plan sponsors and administrators to correct compliance failures that may...more

Pension and Executive Compensation Provisions in the American Rescue Plan Act

Seyfarth Synopsis: On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 ("ARPA"), the $1.9 trillion COVID-19 relief bill. ARPA includes various forms of multiemployer and single employer...more

How to SECURE Your Safe Harbor Plan

Seyfarth Synopsis: The IRS issued Notice 2020-86, which provides guidance on the rules that apply to safe harbor plans that were changed by the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE...more

Happy New Year! The IRS Grants Permission to Celebrate New Year’s Eve

Seyfarth Synopsis: The IRS has announced that the due date for contributions to a single-employer defined benefit pension plan due in 2020, previously extended to January 1, 2021 by the CARES Act, will be considered timely if...more

IRS Provides Additional Clarity on Key SECURE Act Provisions

On December 20th, before the outbreak of COVID-19 and the resulting pandemic, President Trump signed into law the Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”) and the Bipartisan...more

Hybrid Plan Filing Reprieve…. Sort of

Seyfarth Synopsis: The IRS published guidance in its Employee Plans newsletter on August 24, 2020, allowing incomplete determination letter applications to be filed by August 31, 2020, with an opportunity to supplement the...more

Finally! DOL Issues Final Regulations for the E-Delivery of Retirement Plan Disclosures

After a long process, which stretched on for over a decade, on May 27, 2020, the Department of Labor (“DOL”) published final regulations regarding the electronic delivery of required disclosures under the Employee Retirement...more

The IRS Speaks: Coronavirus Distributions From Retirement Plans

Seyfarth Synopsis: The IRS has issued some initial guidance on the coronavirus-related relief for retirement plans (and IRAs) under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) in the form of Q&As on...more

The IRS Speaks: Retirement Plan Coronavirus Loan Relief

Seyfarth Synopsis: The IRS has issued some initial guidance on the coronavirus-related relief for retirement plans (and IRAs) under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) in the form of Q&As on...more

CARES Act Relief: Defined Contribution Plan Provisions

Seyfarth Synopsis: On March 27, 2020, the House of Representatives followed the Senate’s lead in voting overwhelmingly to pass the Coronavirus Aid, Relief, and Economic Security (CARES) Act (the “Act”), which the President...more

401(k) and 403(b) Hardship Distributions and COVID-19 Declared Disaster Areas

Seyfarth Synopsis: The Federal Emergency Management Agency (FEMA) has declared several disaster areas around the United States as a result of the spread of the coronavirus (COVID-19)....more

Whistleblowing Hits Employee Benefits World

Seyfarth Synopsis: Recently a “whistleblower” leaked that the IRS had internally announced an upcoming modification to the very popular voluntary correction program (“VCP”) that would have been a significant disincentive for...more

Proposed Regulations for Electronic Delivery of Retirement Plan Disclosures: The DOL Modernizes the Disclosure Rules

On October 22, 2019, the Department of Labor (DOL) issued proposed regulations providing guidance for retirement plan administrators using electronic delivery for required disclosures, including a new safe harbor....more

Welcome To The 21st Century—The DOL Proposes Changes To Antiquated Electronic Disclosure Rules Under ERISA

Synopsis: The Department of Labor (“DOL”) just issued proposed rule changes governing the disclosure of ERISA-required notices via an electronic format (e.g., emails, intranet sites, etc.). These proposed rules update final...more

Qualified Plan Uncashed Check Guidance Issued Related to Tax Obligations

On August 14, 2019, the IRS issued Revenue Ruling 2019-19, providing guidance to both tax-qualified plan administrators and participants on the tax treatment of plan distribution checks that are not cashed. ...more

IRS Issues Update To Qualified Plan Correction Guidance

In September, the IRS issued Rev. Proc. 2018-52 updating the IRS correction program, i.e., Employee Plans Compliance Resolution System (“EPCRS”). EPCRS allows retirement plan sponsors to correct compliance failures that may...more

Newly Proposed IRS Rules Permit the Use of Forfeitures for QNECs and QMACs

On January 18, 2017, the IRS issued proposed regulations that expand the permitted uses of forfeitures in a 401(k) plan. Under the proposed rules, the definitions of “qualified nonelective contributions” (QNECs) and...more

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