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IRS Extends Anticipated Effective Date for Certain 2024 Proposed RMD Rules Until 2026

Last year, the IRS issued its long-anticipated final (and newly proposed) regulations to address SECURE 1.0 and 2.0 Act changes to the required minimum distribution (“RMD”) rules (Code section 401(a)(9)). The 2024 proposed...more

IRS Ruling Allows Employees to Choose Between Health, Retirement, and Student Loan Benefits

On May 20, 2024, the IRS issued private letter ruling (“PLR”) 202434006 (the “2024 PLR”) that permits employees to allocate an employer contribution among various benefits outside of a cafeteria plan. The IRS has previously...more

IRS Finalizes (and Proposes More) Required Minimum Distribution Rules

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

Final IRS Regulations Update Present Value Calculations for Defined Benefit Plans and Expand Anti-Cutback Relief

Generally, a defined benefit plan provides an accrued benefit commencing at a participant’s Normal Retirement Date that pays a flat benefit over the lifetime of the participant. If a plan provides for a distribution as a...more

Recent IRS Snapshot Suggests Audit Interest in Timing of Employer Deductions of Retroactive Contributions to 401(k) Plans

The IRS recently released an Issue Snapshot, Deductibility of employer contributions to a 401(k) plan made after the end of the tax year, to review the timing rules for employer contribution deductions under Code section...more

IRS Warns Plan Sponsors of ESOP Compliance Risks

On August 9, 2023, the Internal Revenue Service (“IRS”) issued a new notice (IR-2023-144, the “Notice”) cautioning employers “to be alert to a range of compliance issues that can be associated with Employee Stock Ownership...more

Proposed Treasury Regulation on Constructing Yield Curve for Funding Purposes

On June 23, the Treasury published proposed regulations on the methodology for constructing the yield curve that underlies how present values are calculated for defined benefit plans (88 Fed Reg 41047).  The proposed...more

SECURE 2.0 Guidance Process Begins – Self Correction for Eligible Inadvertent Failures Is First Up

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

Recent IRS Guidance Focuses on Rules for Qualified Foreign Pension Funds

At the end of 2022, the Department of the Treasury and the Internal Revenue Service (together, the “IRS”) issued two sets of guidance – a final rule and a proposed rule – addressing the application of certain provisions of...more

IRS Proposed Regulation Addresses Rules Relating to Plan Forfeitures

Historically, the topic of forfeitures has raised many questions for qualified plan administrators- specifically, how and when they can be used.  But there has been little formal guidance from the Department of Treasury and...more

IRS Rules That Payment of 401(h) Account Benefits to Pension-Eligible Active Participants Won’t Jeopardize Plan Qualification

A recent IRS letter ruling provides helpful clarification on the interaction of in-service distributions to active employees (Code section 401(a)(36)) and the requirement that Code section 401(h) accounts provide only retiree...more

IRS Guidance on Excise Tax on Buybacks Clarifies Some Benefits Issues

New Section 4501 of the Internal Revenue Code imposes a 1% excise tax on certain corporate stock repurchases or “corporate buybacks” in excess of $1 million in the taxable year.  The new tax is imposed on the fair market...more

IRS Proposes Making Remote Notarization Permanent for Retirement Plan Elections & Consents

On December 30, the Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released a notice of proposed rules relating to the use of an electronic medium for retirement plan participant elections and...more

IRS Guidance Priorities for 2022-23 Reflect Few New Projects

For many years now, IRS and Treasury have jointly developed a list of areas in which they intend to release guidance – such as regulations, revenue rulings, notices and other published official authority – during the coming...more

New 403(b) Plan Determination Letter Program

Continuing a recent trend to more closely align 403(b) plans with tax-qualified 401(k) plans, the Internal Revenue Service (“IRS”) recently issued Revenue Procedure 2022-40 (November 7, 2022) to create a limited determination...more

2023 Benefit and Contribution Limits

The IRS recently announced that substantially all of the key retirement plan and health and welfare plan limits will increase next year – some significantly due to higher inflation. Notice 2022-55 (Oct. 21, 2022); Rev. Proc....more

IRS Required Minimum Distribution (“RMD”) Relief for Beneficiaries for 2021 and 2022

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

IRS Provides Three-Year Extension for SECURE Act Amendments and Additional Limited Relief

IRS Notice 2022-33 provides extensions to the amendment deadlines for certain provisions of the Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE Act”), the Bipartisan American Miners Act of 2019...more

Summary of Provisions in the Securing a Strong Retirement Act (H.R. 2954)

In June, the Senate committees with jurisdiction over retirement approved their versions of retirement reform legislation. The Senate bills are the Enhancing American Retirement Now Act (unnumbered, the “EARN Act”), which was...more

Surplus Plan Assets Continue to Puzzle IRS and Frustrate Plan Sponsors

Over the years, many plan sponsors have accumulated surplus assets in their pension and welfare benefit programs for various reasons. Typically, surplus assets have been generated in these mature programs through some...more

7/1/2022  /  Excise Tax , IRS , Pensions , Retirement Plan

The IRS’s New Pre-Examination Pilot Program – Key Features and Questions

Earlier this month, the IRS announced a new pilot program under which retirement plan sponsors will be given 90-days notice that their plan has been selected for examination which they may be able to largely avoid by taking...more

IRS Updates LRMs for 403(b) Plans

The IRS recently issued an updated Listing of Required Modifications and Information Package (known as the “LRMs”) for 403(b) plans. These LRMs contain quite a few changes, from simple clarifications and explanatory notes,...more

Administration Budget Proposals Tighten Rules for 409A Violations, VEBA Funding and Indemnity Health Plans

On March 28, the Biden Administration submitted its Fiscal Year 2023 budget proposals reflecting its budget and tax policy priorities, which could surface when Congress resumes work on budget reconciliation. While it is...more

Proposed “One-Bad-Apple” Rules – IRS Takes Another Cut

On March 25, the IRS issued a set of proposed regulations under Internal Revenue (“Code”) section 413(c) and 413(e) addressing multiple employer plans, or “MEPs,” and pooled employer plans, or “PEPs.” 87 Fed. Reg. 17225. We...more

IRS Revamps Minimum Required Distribution Rules

At long last, the Internal Revenue Service issued proposed regulations under Code section 401(a)(9) that take into account the major changes made by the Setting Every Community Up for Retirement Enhancement Act of 2019...more

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