“Top hat plans” —non-qualified deferred compensation plans that can be exempt from most of the requirements of Employee Retirement Income Security Act of 1974 or ERISA—can be a useful tool for employers looking to provide...more
On this episode of “Just Compensation,” the hosts provide an introduction into Section 409A, the complicated tax code provision that governs non-qualified deferred compensation: when does it apply, how do you comply with it,...more
On August 25, the Internal Revenue Service issued Notice 2023-62 (the Notice) delaying implementation of a provision of the SECURE 2.0 Act of 2022 that, commencing in 2024, would have required catch-up contributions by...more
In this episode, the hosts discuss how companies can structure “in-the-money” stock options in order to avoid violating IRS rules governing non-qualified deferred compensation. They also address the benefits and potential...more
On July 26, 2022, the U.S. Department of Labor (DOL) released a proposed amendment to Prohibited Transaction Class Exemption 84-14, known as the Qualified Professional Asset “Manager” (QPAM) exemption. ...more
8/5/2022
/ Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Fiduciary Duty ,
GAAP ,
Internal Revenue Code (IRC) ,
Investment Adviser ,
IRS ,
Notification Requirements ,
Proposed Amendments ,
QPAM ,
Real Party in Interest ,
Recordkeeping Requirements
Hosts Andrew Graw and Megan Monson discuss the American Rescue Plan Act of 2021 (ARPA) as part of the new (third) COVID-19 stimulus relief bill. The ARPA assists qualifying individuals who lose coverage under an employer’s...more
10/14/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Coronavirus/COVID-19 ,
Employee Benefits ,
Employer Group Health Plans ,
Former Employee ,
Hiring & Firing ,
Involuntary Reduction in Force ,
IRS ,
Premium Assistance ,
Premium Subsidies ,
Reduction in Hours ,
Relief Measures ,
Tax Credits
On March 11, President Biden signed into law the American Rescue Plan Act of 2021 (ARPA), which provides temporary premium assistance for health, dental, and vision coverage under the Consolidated Omnibus Budget...more
5/28/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Consolidated Appropriations Act (CAA) ,
Department of Labor (DOL) ,
Eligibility ,
Employer Group Health Plans ,
Guidance Update ,
IRS ,
Joe Biden ,
Notice Requirements ,
Premium Subsidies
On March 11, President Biden signed into law the American Rescue Plan Act of 2021 (ARPA) as part of a new (third) COVID-19 stimulus relief bill. ARPA assists qualifying individuals who lose coverage under an employer’s group...more
3/18/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Enrollment ,
Involuntary Reduction in Force ,
IRS ,
Joe Biden ,
Medicare ,
Medicare Taxes ,
Relief Measures ,
Tax Credits
On August 8, President Trump issued a Memorandum directing the Treasury Department to permit employers to defer the withholding of employees’ social security and railroad retirement taxes through December 31, 2020. On August...more
The Coronavirus Aid, Relief, and Economic Security (CARES) Act allows employers to defer the employer’s portion of the Social Security payroll tax (6.2 percent) (and certain railroad retirement taxes) on wages paid from March...more
On March 11, 2020, the Internal Revenue Service (IRS) issued Notice 2020-15 to clear up concerns about whether high-deductible health plans (HDHP) could cover all costs for testing and treatment of 2019 Novel Coronavirus...more