On April 3, 2025, the Department of Labor (“DOL”) issued Field Assistance Bulletin 2025-02 (the “Bulletin”), which provides guidance related to certain modifications made by the SECURE 2.0 Act of 2022 (“SECURE 2.0”) to the...more
On January 10, 2025, the Treasury Department and the IRS issued Proposed Regulations addressing one of SECURE 2.0’s signature requirements: that all newly established 401(k) plans and 403(b) plans with cash or deferred...more
1/20/2025
/ 401k ,
403(b) Plans ,
Automatic Enrollment ,
Compliance ,
Employee Retirement Income Security Act (ERISA) ,
IRS ,
Proposed Regulation ,
Retirement Plan ,
SECURE Act ,
Tax Reform ,
U.S. Treasury
On October 3, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued Notice 2024-73 (the “Notice”) to clarify eligibility rules for long-term, part-time (“LTPT”) employees in 403(b)...more
On August 19, 2024, the Internal Revenue Service (“IRS”) issued Notice 2024-63 (the “Notice”) for retirement plan sponsors that provide, or may wish to provide, matching contributions based on qualified student loan payments...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
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
Over the past several years, there has been a growing interest in enhancing employee benefit programs to help employees save for emergencies. Employers and service providers have developed a number of different types of...more
On November 24, 2023, the IRS issued a Notice of Proposed Rulemaking, which provides long-awaited proposed regulations regarding the “long-term, part-time employees” rules under the SECURE Act of 2019 (“SECURE 1.0”) and the...more
Last week, the IRS issued Notice 2023-54 (“Notice”) that provides a variety of relief for both plan sponsors and IRA providers, along with participants/IRA owners and their beneficiaries, while we await the final Code section...more
The IRS has issued interim guidance to address the changes made by section 305 of SECURE 2.0 to the self-correction program under the IRS Employee Plans Compliance Resolution System (commonly referred to as “EPCRS”). While...more
The wide-ranging SECURE 2.0 Act of 2022 (“SECURE 2.0”) radically altered the retirement plan landscape, and is likely to create a significant number of action items for sponsors of retirement plans for tax-exempt entities and...more
3/14/2023
/ 401k ,
403(b) Plans ,
457(b) Plans ,
Church Plans ,
Compensation & Benefits ,
Employee Benefits ,
Multiemployer Plan ,
New Legislation ,
Regulatory Reform ,
Retirement Plan ,
SECURE Act ,
Tax Exemptions
With its more than 90 retirement provisions, SECURE 2.0 has set out to improve the retirement system and increase retirement savings. Notably, included are measures to improve upon the handling of defined benefit plans. Here,...more
Yesterday, the Senate passed the Consolidated Appropriations Act of 2023 (the “CAA”) to fund the government through September 30, 2023. Division T of the legislation is the SECURE 2.0 Act of 2022 (“SECURE 2.0”), which builds...more
As the end of 2022 approaches, it’s again time for plan sponsors to review their plan documents and plan operations to ensure compliance with increasingly complex qualification requirements and moving deadlines. While there...more
The IRS provided welcome relief from Code section 401(a)(9) RMD compliance for 2021 and 2022 for post-death distributions to beneficiaries under IRAs and defined contribution plans. IRS Notice 2022-53 (“Notice”). In short –...more
Following up on the SECURE Act and other recent plan amendment extensions in Notice 2022-33, the IRS has issued Notice 2022-45 (Sept. 27, 2022) to extend the amendment deadlines for the remaining provisions of the Coronavirus...more
On November 5, 2020, the Internal Revenue Service (“IRS”) released final regulations under section 401(a)(9) of the Internal Revenue Code (“IRC”). 85 Fed. Reg. 72472 (Nov. 12, 2020). The final regulations, which closely...more
On June 23, the Internal Revenue Service (“IRS”) issued Notice 2020-51, which provides much-needed guidance on how defined contribution plans (including 403(b) and governmental 457(b) plans) and IRAs implement the waiver of...more
6/26/2020
/ Benefit Plan Sponsors ,
CARES Act ,
Defined Contribution Plans ,
Employee Benefits ,
Individual Retirement Account (IRA) ,
IRA Rollovers ,
IRS ,
Required Minimum Distributions ,
Retirement ,
Retirement Plan ,
Retirement Plan Providers ,
SECURE Act
The Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), the largest package of retirement system reforms in over a decade, was enacted on December 20, 2019. ...more
2/13/2020
/ 401k ,
Compensation & Benefits ,
Employee Benefits ,
Form 5500 ,
Individual Retirement Account (IRA) ,
New Legislation ,
Part-Time Employees ,
Regulatory Reform ,
Required Minimum Distributions ,
Retirement ,
Retirement Plan ,
Safe Harbors ,
SECURE Act ,
Tax Planning ,
Tax Rates
The Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), the largest package of retirement system reforms in over a decade, was enacted on December 20, 2019. Many of the provisions in the...more
1/23/2020
/ 401k ,
403(b) Plans ,
Benefit Plan Sponsors ,
Compensation & Benefits ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Contributions ,
Fiduciary Duty ,
Final Rules ,
Form 5500 ,
Health and Welfare Plans ,
Individual Retirement Account (IRA) ,
Internal Revenue Code (IRC) ,
New Legislation ,
Paid Family Leave Law ,
PCORI ,
QACA ,
Required Minimum Distributions ,
Retirement ,
Retirement Plan ,
Safe Harbors ,
SECURE Act ,
Tax Credits ,
Tax Planning ,
Unrelated Business Income Tax
In recent years, many defined benefit (“DB”) pension plan sponsors have taken action to limit ongoing coverage and benefit accruals of their DB plans. Over time these plans may have difficulty continuing to satisfy the...more
1/13/2020
/ Benefit Plan Sponsors ,
Best Practices ,
Compensation & Benefits ,
Compliance ,
Defined Benefit Plans ,
Defined Contribution Plans ,
Employee Benefits ,
Employer Liability Issues ,
IRS ,
Minimum Participation Rules ,
New Rules ,
Non-Discrimination Rules ,
Pension Reform ,
Plan Administrators ,
Retirement Plan ,
Retirement Plan Providers ,
SECURE Act ,
U.S. Treasury