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
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
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
SECURE 2.0 has brought about changes to IRAs of all types. To help better understand these modifications, we examine the differences in the new laws governing traditional IRA and Roth IRA accounts under SECURE 2.0 against...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
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
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
Recent IRS Notice 2022-6 updates longstanding guidance on when a series of payments from an individual account under a tax-favored retirement plan is considered a series of “substantially equal periodic payments”. Under Code...more
You may have changed the way hardship withdrawals are made from your 401(k) plan a couple of years ago to comply with changes in the law, but did you amend your plan? And for amendments to required minimum distributions that...more
Securing a Strong Retirement Act of 2021 as marked up by the House Ways and Means Committee on May 5, 2021....more
While we await proposed regulations under Code section 401(a)(9) to reflect the significant changes made to the required minimum distribution (“RMD”) rules under the SECURE Act, the 2020 IRS Publication 590-B for IRA...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
Many of the provisions of the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”) do not apply to non-electing church plans, but some do, notably those dealing with certain 403(b)(9) plans and...more
2/11/2020
/ 403(b) Plans ,
Church Plans ,
Compensation & Benefits ,
Distribution Rules ,
Employee Benefits ,
New Legislation ,
Non-Discrimination Rules ,
Part-Time Employees ,
Recordkeeping Requirements ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Required Minimum Distributions ,
Retirement ,
Retirement Plan ,
SECURE Act ,
Tax Planning ,
Termination Rights
IRA providers were concerned with not being able to “stop the presses” when it came to notices being provided in January to IRA owners regarding the need to take 2020 minimum required distributions (“MRDs”)....more
1/30/2020
/ 401k ,
403(b) Plans ,
Compensation & Benefits ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Individual Retirement Account (IRA) ,
IRS ,
Multiemployer Plan ,
New Legislation ,
Pensions ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Required Minimum Distributions ,
Retirement ,
Retirement Plan ,
SECURE Act ,
Tax Planning
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
On Thursday, December 19, the Senate passed two spending bills to fund the government through September 30, 2020, one of which (H.R. 1865, the “Further Consolidated Appropriations Act of 2020” or the “Act”) contains the...more
1/10/2020
/ 401k ,
403(b) Plans ,
457(b) Plans ,
529 Plans ,
Affordable Care Act ,
Benefit Plan Sponsors ,
Cadillac Tax ,
Church Plans ,
Consolidated Appropriations Act (CAA) ,
Defined Benefit Plans ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Individual Retirement Account (IRA) ,
Lifetime Income Disclosures ,
Medicare ,
Non-Discrimination Rules ,
Part-Time Employees ,
PBGC ,
Penalties ,
Plan Administrators ,
Pooled Registration Pension Plans ,
Portability ,
Prescription Drug Coverage ,
QACA ,
Repeal ,
Required Minimum Distributions ,
Retirement Plan ,
Retirement Plan Providers ,
Safe Harbors ,
SECURE Act ,
Small Employer Plans (SEPs)