News & Analysis as of

Internal Revenue Service 401k Fiduciary Duty

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Kelley Drye & Warren LLP

Simplified Option for Correcting Certain Retirement Plan Failures

Earlier this year, the U.S. Department of Labor (“DOL”) amended its Voluntary Fiduciary Compliance Program (“VFCP”) to provide retirement plan sponsors with a simplified option for correcting certain specified prohibited...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - May 2025

The May Monthly Minute brings you up-to-date on mental health parity enforcement relief, as well as smoker surcharge and prohibited transaction litigation. Nonenforcement of 2024 Mental Health Parity Regulations - Earlier...more

Alston & Bird

IRS Proposes Changes to 401(k) Catch-Up Contributions

Alston & Bird on

Our Employee Benefits & Executive Compensation Group discusses what plan sponsors and fiduciaries need to know about the Internal Revenue Service’s proposed changes for employees 50 or older who make additional elective...more

Kaufman & Canoles

ESOPs Benefits & Compensation - Q1 2025 Client Alert

Kaufman & Canoles on

Happy Spring from the Kaufman & Canoles ESOPs, Benefits & Compensation team! We hope you’re shaking off the winter blues and ready for another round of benefits updates. ...more

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

Bricker Graydon LLP on

Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more

Miller Canfield

IRS Issues Proposed Regulations on Secure 2.0 Catch-Up Provisions

Miller Canfield on

The IRS issued Proposed Regulations last month which provide helpful clarity for employers on how to implement and comply with two new SECURE 2.0 provisions relating to catch-up contributions....more

Shipman & Goodwin LLP

Plan Forfeiture Litigation: A Trend to Watch

Shipman & Goodwin LLP on

The most recent wave of ERISA litigation is focused on the use of plan forfeitures in 401(k) plans, with the newest case, Armenta v. WillScot Mobile Mini Holdings Corp. being filed just last week. Although, for years, many...more

DLA Piper

Qualified Retirement Plans Agenda

DLA Piper on

Our qualified retirement plans agenda outlines current legislative, litigation, and other developments concerning tax-qualified retirement plans. Sponsors are encouraged to be aware of these issues and assess whether any...more

Warner Norcross + Judd

Attention: Forfeitures and Other Unallocated Accounts in Retirement Plans Need Review

Warner Norcross + Judd on

Recent developments spotlight issues with forfeiture and other unallocated accounts in defined contribution retirement plans, such as 401(k) plans: •The IRS has set the deadline for plan forfeiture use. •Participants in...more

Foley & Lardner LLP

Five Things on the Department of Labor’s Radar for Employee Benefit Plans

Foley & Lardner LLP on

All qualified retirement plans are subject to a myriad of requirements of the Employee Retirement Income Security Act of 1974, as amended (ERISA). The United States Department of Labor (DOL) is charged with enforcing the...more

Jones Day

Another 401(k) Plan Sponsor Faces Novel Suit Regarding its Use of Forfeiture Funds

Jones Day on

The Employee Retirement Income Security Act ("ERISA") plaintiffs' bar has found a new way to allege that 401(k) plan sponsors have breached their fiduciary duty....more

Allen Barron, Inc.

What Can A Tax Attorney Do For You? A Podcast With Janathan Allen

Allen Barron, Inc. on

Janathan Allen discusses what a tax attorney brings to the table that many other don’t. Ms. Allen notes that many attorneys don’t like numbers and yet there is so much in the business world that focuses upon the numbers...more

Dickinson Wright

Mastering Retirement Plan Forfeitures: A Deep Dive into IRS’s 2023 Proposals & Fiduciary Litigation Trends

Dickinson Wright on

When a participant terminates employment without being fully vested in their qualified retirement plan account, the non-vested portion of the account is a “forfeiture.” While forfeitures are a common element of most...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - March 2023

The March Monthly Minute highlights new proposed deadlines for use of retirement plan forfeitures, unsuccessful efforts to overturn the final ESG rule, and ACA penalty increases for 2024. Sorry Not Sorry: Biden Vetoes...more

Holland & Hart - The Benefits Dial

Should I Pay Or Should I No(t) Now: Which Expenses Can be Paid with Plan Assets?

One question that often comes up is whether an expense related to an ERISA plan can be paid with plan assets. The decision of whether to use ERISA plan assets to pay an expense is an ERISA fiduciary decision. With the recent...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

I get what Fidelity is trying to do

People are scratching their heads, the Department of Labor (DOL) had grave concerns over offering crypto in 401(k) plans, and less than a week later, Fidelity announced their plan to offer Bitcoin as an option for plan...more

McDermott Will & Emery

When Are Cryptocurrencies Appropriate Investments for Retirement Plans and IRAs? DOL Cautions 401(k) Plan Fiduciaries to Exercise...

Cryptocurrencies and digital assets—such as bitcoin, ether and non-fungible tokens (NFTs)—have become some of the hottest investment products in recent years. The growing interest has inevitably led to retirement plan...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - March 2022

In the March Monthly Minute, we review IRS proposed regulations implementing the SECURE Act, DOL guidance on cryptocurrency investments, and the extended National Emergency “Outbreak Period” guidance. Crypto-Curious vs....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Sometimes, it’s the luck of the draw with a government agent

I have been an ERISA attorney for 23 years, I have seen a lot of strange things that plan sponsors have done to risk the ire of the Internal Revenue Service (IRS) and the Department of Labor (DOL). Many of these strange...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Rosenbaum Law Firm Review - June 2021

Plan Provider Gimmicks You Need To be Aware Of - The retirement plan business is heavily competitive and so much of that deals with marketing. As a retirement plan sponsor, you need to separate the fluff from the real...more

Holland & Hart LLP

Under the Radar: Employee Benefit Developments in 2020

Holland & Hart LLP on

The story of the year has been the coronavirus. COVID-19 has dominated news headlines, social media, and virtually every aspect of our lives. The virus has likewise dominated legal and tax news. Lawmakers and agencies have...more

Woods Rogers

COVID-19 and Retirement Plan Fiduciary Obligations

Woods Rogers on

Under ERISA, the federal law that regulates retirement and 401(k) plans, plan fiduciaries are required to prudently administer the plan, select and monitor plan investments and sufficiently diversify plan assets to minimize...more

Carlton Fields

Alternative Retirement Plan Investments: A Retirement Plan Committee Checklist

Carlton Fields on

Participants do not always prefer the investment choices retirement plans offer. Whether participants want additional ways to diversify their portfolios or have other reasons, participants are asking retirement plan sponsors...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Picking the cheapest provider can be a breach of fiduciary duty

When it comes to health and fitness, you constantly hear studies about what foods fight or cause cancer. Of course, those studies are then debunked. I remember how oat bran was cited to cut down on cholesterol and how...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Bad advice can create bad IRS and DOL assumptions

A financial advisor called me and asked me if there was a problem that an insurance policy paid by a 401(k) plan had the policy in the name of the participant. Considering it was a plan asset, I thought so. If the participant...more

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