News & Analysis as of

Internal Revenue Service Forfeiture

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.  
Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Timely use forfeitures

ERISA is filled with traps for the unwary. Some are complex, hiding in layers of regulatory nuance. Others are deceptively simple—like plan forfeitures. Yes, I’m talking about those dollars left behind when participants fail...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

The Wagner Law Group

Update – Recent Developments in Forfeiture Cases

The Wagner Law Group on

The Wagner Law Group continues to monitor the recent flood of retirement plan “forfeiture” litigation. This alert is our eighth update reporting on and analyzing the nature of the claims raised by plaintiffs, the defenses...more

Quarles & Brady LLP

Forfeiture Funds: Legal Requirements, Permitted Uses, and Litigation Risk Management

Quarles & Brady LLP on

Forfeiture funds in 401(k) plans represent a unique asset pool with specific regulatory requirements and practical applications. Forfeiture funds arise when participants terminate employment with the company before becoming...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The end of forfeitures to reduce contributions is inevitable

Recently had a client going through an Internal Revenue Service (IRS) audit and while talking to an agent, they didn’t disagree with my theory that the idea of being able to reduce employer contributions through forfeitures...more

Warner Norcross + Judd

Attention Auto Suppliers: Don’t Leave Money on the Table Through Unused Retirement Forfeitures and Unallocated Accounts

We understand that running an automotive supplier business involves more than just industry-specific issues. That's why we regularly provide important insights and tips on broader legal trends to help you navigate challenges...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

Kaufman & Canoles

ESOPs, Benefits & Compensation Q2 2024 Client Update

Kaufman & Canoles on

On behalf of the ESOPs, Benefits & Compensation team, we hope your Summer is off to a great start. In the time of family vacations and out-of-office replies, the pace of employee benefits changes—both large and small—remains...more

UB Greensfelder LLP

New Developments in 401(k) Plan Forfeiture Lawsuits: Advice for Plan Sponsors

UB Greensfelder LLP on

401(k) plan sponsors are seeing a string of lawsuits challenging their use of forfeitures to offset matching contributions. In the most recent suit, plaintiffs claimed that a 401(k) plan sponsor violated its fiduciary duties...more

Jackson Lewis P.C.

Use of Plan Forfeitures Not the Slam Dunk It Used to Be

Jackson Lewis P.C. on

A recent rash of class action lawsuits in California claim that using forfeitures to reduce future employer contributions to tax-qualified retirement plans runs afoul of the Employee Retirement Income Security Act (ERISA)....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

Verrill

Use of Retirement Plan Forfeitures: The IRS Proposed Regulations, Recent Litigation, and the DOL’s Position

Verrill on

In five recently filed class action lawsuits, 401(k) plan participants allege that plan fiduciaries violated ERISA by using plan forfeitures to offset employer contributions instead of paying plan expenses. The use of...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

Groom Law Group, Chartered

IRS Updates Regulations for Use and Timing of Forfeitures

Over the years, the Internal Revenue (IRS)/Treasury had an item on their annual guidance plan to update the existing regulations on forfeitures. Well, that guidance is finally here in the form of proposed regulations and it...more

McDermott Will & Emery

Changing the Rules of the Game for Retirement Plans

McDermott Will & Emery on

Earlier this year, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations on the use of forfeitures by tax-qualified retirement plans. The changes, published in the Federal Register,...more

Morrison & Foerster LLP

What Is an 83(b) Election, and Do I Need to File One?

If you’re reading this, chances are this is not the first time you’ve heard of the 83(b) election (and if it is, then definitely keep reading). The “83” in “83(b) election” refers to Section 83 of the Internal Revenue Code,...more

Faegre Drinker Biddle & Reath LLP

Use of Forfeitures in Qualified Retirement Plans

On February 27, 2023, the IRS and the Department of Treasury published proposed regulations regarding the use of forfeitures in qualified retirement plans. If finalized, the proposed rule will be effective for plan years...more

Jackson Lewis P.C.

IRS Gets Its Act Together For Forfeiture Rules

Jackson Lewis P.C. on

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

Kilpatrick

Use of Forfeitures in Defined Contribution Plans

Kilpatrick on

In a 2010 newsletter, the IRS announced that forfeitures under a 401(k) plan or other defined contribution plan must be promptly used and not allowed to accumulate over several years. In February, the IRS proposed...more

Harris Beach Murtha PLLC

IRS Issues Proposed Regulations Governing the Use of Forfeitures in Qualified Retirement Plans

The IRS recently issued Proposed Regulations that clarify and update existing rules governing how and when forfeitures must be used in qualified defined contribution (e.g., 401(k)) and defined benefit retirement plans. ...more

Morgan Lewis - ML Benefits

IRS Proposes One-Year Limit on Use of Forfeitures in Defined Contribution Plans

The Internal Revenue Service (IRS) recently issued proposed regulations that would require forfeitures in defined contribution plans—i.e., unvested benefits forfeited by terminating defined contribution plan participants—to...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

Warner Norcross + Judd

Proposed Treasury Regulations Impose Hard Deadline and Requirements on Forfeitures in Defined Contribution Plans

Warner Norcross + Judd on

The U.S. Department of the Treasury has recently proposed new regulations that clarify when and for what purposes defined contribution plans — such as 401(k) plans — may use forfeitures. These regulations are proposed to...more

Verrill

Proposed Regulations on How to Use Forfeiture Accounts: Helpful Guidance and a Great Reminder to Plan Sponsors

Verrill on

On February 27, 2023, the IRS published proposed regulations on the use of forfeitures in qualified retirement plans. For defined contribution plans, the regulations provide welcome clarity on what forfeitures can be used for...more

Ballard Spahr LLP

Proposed Treasury Regulations on Forfeitures Would Require Changes to Tax-Qualified Retirement Plans

Ballard Spahr LLP on

The U.S. Treasury Department issued proposed regulations regarding the treatment of forfeited amounts in tax-qualified defined benefit and defined contribution retirement plans. The February 27, 2023 proposed regulations, if...more

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