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Secure Act 2.0 – Summary of Key Provisions

The House and Senate are moving forward on several versions of legislation, which are collectively known as the “Secure Act 2.0” because they would build off of the Secure Act, the last major retirement plan legislation...more

IRS Announces Pre-Audit Compliance Pilot Program

On June 3, 2022, the IRS announced a new pre-audit compliance program for retirement plans beginning immediately in June 2022 (the “Pilot Program”). Under the Pilot Program, the IRS will send a pre-audit letter to plan...more

IRS Extends Remote Notarization Relief

On June 24, 2021, the Internal Revenue Service (“IRS”) released Notice 2021-40, which extended relief from the “physical presence” requirement for witnessing by plan representatives or notaries of spousal consents through...more

Department of Labor Issues Missing Participant Guidance for Retirement Plans

The Department of Labor (DOL) has issued long-awaited guidance on what it views as appropriate procedures for retirement plans to locate missing or nonresponsive participants. Plan sponsors and fiduciaries of all retirement...more

IRS Extends Relief for Remote Notarization of Spousal Consents

In June, the IRS provided temporary relief that allows for spousal consents for retirement plan loans or distributions to be witnessed remotely through audio visual equipment by a notary public in accordance with a state...more

IRS Releases Detailed Guidance on CARES Withdrawal and Loan Relief

On June 19, 2020, the Internal Revenue Service (“IRS”) released guidance (Notice 2020-50) clarifying many aspects of the retirement plan withdrawal and loan relief provisions of the Coronavirus Aid, Relief, and Economic...more

IRS Allows for Remote Notarizations for Retirement Plan Withdrawals

Congress acted swiftly to allow participants greater access to their retirement plan funds through special withdrawal and loan provisions in recognition of the financial impacts of the COVID-19 pandemic. See our blog post on...more

Changes to Minimum Distribution Rules

The Secure Act is the most significant legislation affecting qualified retirement plans in more than a decade. (See our prior post summarizing key changes.) Changes to the minimum distribution rules are among the most...more

IRS Issues Rules for Correcting 403(b) Plan Document Defects

Nonprofit or governmental employers that sponsor 403(b) plans generally have until March 31, 2020, to correct any defects in their 403(b) plan documents by adopting a pre-approved plan document or by amending their...more

IRS Reopens Determination Letter Program for Cash Balance Plans and Plan Mergers

The IRS has announced that it is reopening its determination letter program for cash balance plans on a temporary basis and for merged plans on an ongoing basis. The IRS determination letter program allows plan sponsors of...more

IRS Updates Operational Compliance List for Qualified Retirement Plans

The IRS has published its Operational Compliance List for 2019, which reflects legislative or regulatory changes that may impact the administration of qualified retirement plans. Generally, plan amendments incorporating...more

IRS Reopens Retiree Lump Sum Windows

In 2015, the IRS limited the de-risking options available to defined benefit pension plans by effectively prohibiting lump sum windows to retirees who are currently receiving annuity payments (known as “retiree lump sum...more

IRS Retirement Plan Correction Program to Go Paperless

The IRS will begin accepting applications and payments under its Voluntary Correction Program (VCP) online through the www.pay.gov website beginning on January 1, 2019. Plan sponsors will continue to be permitted to file VCP...more

Executive Order Seeks to Reduce Retirement Plan Burdens and Costs

On August 31, 2018, President Trump issued an Executive Order on “Strengthening Retirement Security in America.” The Executive Order is intended to set the policy for the Department of Labor (DOL) and the IRS in three...more

Funding 401(k) Corrective Contributions with Forfeitures

The IRS has issued final regulations allowing forfeitures under a 401(k) plan to be used to fund corrective contributions. IRS rules require forfeitures under a plan to be used as soon as possible to pay administrative...more

IRS Updates VCP User Fees

The IRS has revised its user fees for the Voluntary Correction Program (VCP) effective for submissions made on or after January 2, 2018. VCP is an IRS program that allows plan sponsors to correct failures involving a...more

Tax Reform’s Impact on Qualified Retirement Plans

House Republicans this week released much-anticipated legislation to reform individual and corporate income taxation. Titled the “Tax Cuts and Jobs Act,” the legislation proposes substantial revisions to the Internal Revenue...more

IRS Issues Memo on Missing Participant Search Standards

On October 19th, the IRS released a memorandum titled “Missing Participants and Beneficiaries and Required Minimum Distributions” (the “Memo”) to its plan auditors that provides guidelines for when a plan’s efforts to locate...more

2018 Benefit Limits

Retirement Plan Limits - The IRS updated very few of the retirement plan limits effective for the plan year that begins on or after January 1, 2018. Social Security Tax and Wage Base - For calendar year 2018, the...more

Hurricane Relief Legislation for Retirement Plans

We addressed hurricane relief for retirement plans offered by the IRS and other agencies in previous blog posts While the IRS relief allows for easier access to retirement funds on account of losses due to the recent...more

IRS Allows Easier Access to Retirement Funds for Hurricane Harvey Victims

The IRS issued an announcement that may allow participants and beneficiaries of 401(k) plans or 403(b) plans that have been affected by Hurricane Harvey easier access to their retirement funds until January 31,...more

IRS Provides Guidance for the Post-Determination Letter Era

In July of 2015, the IRS announced that it would end its regular determination letter program for individually designed plans effective January 1, 2017. At the time of this announcement, many plan sponsors and other...more

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