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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

Student Loan Match – Repay Student Loans and Save For Retirement

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

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

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

DOL Seeks Input on SECURE 2.0 Changes

On August 11, 2023, the Department of Labor (“DOL”) issued a Request for Information (“RFI”) asking for stakeholder input on a number of regulatory issues related to the SECURE 2.0 Act. The wide-ranging RFI seeks feedback on...more

Additional Required Minimum Distribution Relief Following SECURE 2.0 Act Changes

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 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

Tax-Exempt and Church Plan Highlights From SECURE 2.0

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

Traditional and Roth IRA Changes Under SECURE 2.0

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

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

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

Year-End Amendments Extended – CARES and 2020 Relief Act

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

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 House-Passed SECURE 2.0 Legislation

On March 29, the House overwhelmingly passed H.R. 2954, the Securing a Strong Retirement Act of 2021 (“SSRA”), by a vote of 414-5. This alert contains Groom’s summary of the legislation as passed by the chamber....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

IRS Announces Opening of the Second 403(b) Pre-Approved Plan Cycle

Background on the 403(b) Pre-Approved Plan Program - In 2013, the IRS began accepting prototype and volume submitter 403(b) plans (now referred to collectively as “pre-approved” plans) in the first-ever 403(b) remedial...more

Comparison of Provisions in SECURE 2.0 and Cardin-Portman

Groom has prepared a comparison here of the provisions in two key retirement bills being considered by the 117th Congress: the Securing a Strong Retirement Act of 2021 (H.R. 2954, “SECURE 2.0”) and the Retirement Security &...more

Updated IRS Publication 590-B Provides Insights On Post-Death RMD Rules After the SECURE Act

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

IRS Guidance on SECURE Act Provides More Detail on Changes to Safe Harbor Plans

The Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE Act”) made several changes to the rules for certain safe harbor 401(k) plans. One change increased the cap on automatic enrollment safe harbor...more

IRS Issues Final Regulations Updating Minimum Required Distribution Rules

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

Round One of SECURE Act IRS Guidance Clarifies Some Key Issues for Retirement Plans

IRS Notice 2020-68 (Notice) provides the first round of guidance on a number of provisions under the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) and the Bipartisan American Miners Act of...more

IRS Guidance on 2020 Required Minimum Distribution Waivers and 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

SECURE Act – Impact on 401(k) Plan Sponsors

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

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