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IRS Interim Guidance Under Secure 2.0 On “Inadvertent Benefit Overpayments”

Among the provisions of SECURE 2.0 (effective December 29, 2022) welcomed by plan sponsors were the additions to the Internal Revenue Code that allow qualified plans to refrain from trying to recoup an “inadvertent benefit...more

IRS Gets Its Act Together For Forfeiture Rules

The February 24, 2023, issuance by the IRS of proposed regulations on the use of forfeitures in qualified retirement plans provides some welcome clarity, regulatory house cleaning, and relief for plan sponsors. With a...more

Dealing With Undocumented Workers In ERISA Plans

Whether because of the tight U.S. labor market or flawed onboarding processes, many undocumented workers are becoming participants and accruing benefits in ERISA-governed employee benefit plans. Dealing with such plan...more

The IRS Released The Final Regulations For Plan Loan Offset Rollovers

The IRS released final regulations on the provisions of the Tax Cuts and Jobs Act (“TCJA”) that added Section 402(c)(3) of the Internal Revenue Code, effective January 1, 2018, special rollover relief for qualified plan loan...more

Determination Letter Rationing: IRS Reveals the Brave New World

Last year’s announcement by the Internal Revenue Service (IRS) of the elimination of the current five-year remedial amendment cycle system for determination letter approval of restated individually-designed qualified plan...more

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