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Hello… Goodbye… Hello Again: New IRS FAQs Discuss Rehires and Bona Fide Retirements In Light of COVID-Related Labor Shortages

Seyfarth Synopsis: The IRS recently sought to reassure employers that they will not jeopardize their retirement plan’s tax qualified status if they permit employees who have a bona fide separation from service to take a...more

One-Year Expiration of Outbreak Period: Pandemic Rages On, But It’s (Probably) Time to Pay Your COBRA Premiums

Seyfarth Synopsis: As you’ll recall, last Spring, the DOL and IRS issued guidelines providing relief from certain deadlines for employee benefit plans, retroactive to March 1, 2020 (i.e., the beginning of the COVID-19...more

Out for a Penny, Out for a Pound? IRS Provides Employees Opportunity to Cancel Non-Qualified Deferral Elections through...

Seyfarth Synopsis: As Seyfarth has blogged about on multiple occasions, the CARES Act provides participants in tax-qualified retirement plans the opportunity to request distributions on a tax-favored basis by self-certifying...more

Executive Compensation at Tax-Exempt Organizations Back in the Limelight – IRS Issues New Guidance

Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more

IRS Expands Determination Letter Program on a Limited Basis For Certain Individually Designed Plans

On May 1, 2019, the Internal Revenue Service (IRS) issued guidance re-opening its storied determination letter program to hybrid plans and certain plans impacted by plan mergers....more

Good News / Bad News: The IRS has Released Interim Guidance Regarding the New Excess Compensation Excise Tax Applicable to...

Just in time for the New Year and notwithstanding the government shutdown, on December 31, 2018, the Internal Revenue Service (“IRS”) issued Notice 2019-09 (the “Notice”), which provides interim guidance on the new excise tax...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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