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
3/3/2023
/ Comment Period ,
Defined Benefit Plans ,
Employee Benefits ,
Forfeiture ,
IRS ,
Plan Administrators ,
Proposed Rules ,
Regulatory Agenda ,
Retirement Plan ,
Tax Reform ,
U.S. Treasury
Concerns surrounding retirement plan overpayments and measures by which to correct certain plan failures have been addressed with the passage of SECURE 2.0. On February 15, 2023 at 2:00 – 2:30 p.m. ET, in the sixth segment of...more
On December 12, 2022, the Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released final regulations that provide reporting relief for ACA reporting— specifically, Forms 1095-B and 1095-C...more
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
On February 18, 2022, President Biden again formally extended the COVID-19 National Emergency, which was set to expire on March 1, 2022. As explained in detail in our previous alerts, this most recent extension means that...more
On November 22, 2021, the Department of Treasury and the IRS issued proposed regulations generally intended to provide Form 1095-B and 1095-C reporting relief. Under the statutory language of the ACA, reporting entities are...more
As we approach the end of 2021, it’s again time for sponsors of 401(a) and 403(b) plans to review their plan documents and plan operations to ensure compliance with increasingly complex qualification requirements. While...more
The IRS recently announced (Notice 2021-61, Nov. 4, 2021) that many of the key pension limits will increase next year – some significantly due to higher inflation. The Social Security Administration and PBGC also recently...more
On October 6, 2021, the IRS released Notice 2021-58 (the “Notice”), which provides yet another round of guidance on the application of extended deadlines for COBRA elections and payments due to COVID-19. This guidance expands...more
With rising rates of COVID-19 cases in the past few months, employers have been increasingly interested in exploring incentives designed to increase COVID-19 vaccination rates among employees. One idea that has been gaining...more
The Department of Labor (“DOL”), Department of the Treasury (the “Treasury”), and Pension Benefit Guaranty Corporation (“PBGC”) (collectively, the “Agencies”) recently released a notice of proposed revisions to the Form 5500...more
On July 26, 2021, the IRS released Notice 2021-46 (the “Notice”), which provides new guidance on the 100% COBRA premium subsidies (the “Subsidies”) and the related tax credit under the American Rescue Plan Act of 2021 (March...more
The Department of Labor (“DOL”) recently issued an information letter, DOL Information Letter 06-14-2021 (the “Letter”), addressing the question of whether the ERISA claim regulation requires production of an audio recording...more
Since the American Rescue Plan Act (“ARPA”) was enacted in March 2021, employers and insurers have been diligently familiarizing themselves with the rules for administering the temporary 100% COBRA premium subsidy established...more
On May 18, 2021, the IRS released its highly anticipated guidance on the 100% COBRA premium subsidies (the “Subsidy”) and the related tax credit under the American Rescue Plan Act of 2021 (March 11, 2021) (“ARPA”) in Notice...more
On April 7, 2021, the Department of Labor (“DOL”) released initial guidance regarding the 100% COBRA premium subsidies under the American Rescue Plan Act of 2021 (“ARP”), and also issued model notices that can be used in...more
In the early morning hours of February 27, the House of Representatives narrowly passed H.R. 1319, the American Rescue Plan Act (the “Rescue Plan”), by a vote of 219-212. The Senate will now take up the sweeping $1.9 trillion...more
On February 17th, we posted an alert that the COVID-19 extensions that the DOL and IRS had issued last year as part of their “Joint Notice” were set to expire at midnight on February 28th. For weeks, we have been asking DOL...more
On February 18, 2021, the IRS released Notice 2021-15 (the “Notice”) interpreting section 214 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (the “Act”), enacted as Division EE of the Consolidated...more
As the COVID-19 pandemic began to overwhelm the country last spring, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) became concerned that the disruption caused by the pandemic would create...more
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) provided employers valuable relief from the economic stress caused by the COVID-19 pandemic, by creating access to loans under the Paycheck Protection...more
On July 8, 2020, the IRS released Notice 2020-54 (the “Notice”), which mandates 2020 W-2 reporting of qualified sick and family leave wages paid to employees under the Families First Coronavirus Response Act (the Act). ...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
On June 19, 2020, the Internal Revenue Service (“IRS”) issued Notice 2020-50, which provides clarity to plan administrators and participants on coronavirus-related loans and distributions following the passage of the...more
The IRS released two Notices this week related to cafeteria plans and flexible spending arrangements (“FSAs”). Notice 2020-29 provides relief for cafeteria plans in response to the current COVID-19 pandemic, and Notice...more