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In a previous article, we outlined the IRS’ proposed regulations implementing Section 603 of the SECURE 2.0 Act, which requires certain high earners to make catch-up contributions on a Roth basis beginning in 2026. ...more
Proposed Treasury regulations relating to catch-up contributions were issued in January of 2025 that include guidance for the mandatory Roth catch-up requirement, which was first provided under section 603 of Division T of...more
On July 19, 2024, the Internal Revenue Service (“IRS”) issued final regulations (“2024 regulations”) regarding the SECURE Act of 2019 and the SECURE Act 2.0 of 2022, which apply to 401(a) plans, 401(k) plans, traditional and...more
Since 2002, employers have been able to make catch-up salary deferrals to their employees in their 401(k), 403(b), and governmental 457(b) plans beginning in the calendar year in which they turn 50 (the “Age 50 Catch-up”)....more
The Secure 2.0 Act (Secure 2.0), a sweeping retirement bill included in Division T of the Consolidated Appropriations Act of 2023, was a major bipartisan accomplishment of the 117th Congress. The bill included 82 provisions...more
Section 603 of the SECURE 2.0 Act of 2022 (“Section 603”) implements changes to catch-up contributions and is applicable to employers who maintain a 401(k), 403(b), or 457(b) plan with participants who are age 50 and older...more
The IRS issued guidance on Friday, August 25, 2023, under Section 603 of the SECURE 2.0 Act of 2022, which requires age-based catch-up contributions by high-paid employees to a 401(k), 403(b), or governmental 457(b) plan to...more
As signed into law, Section 603 of the SECURE 2.0 Act of 2022 (SECURE 2.0) required that effective as of January 1, 2024, participants in 401(k) plans, 403(b) plans, or governmental 457(b) plans, who were age 50 or older and...more
In welcome news to employers, recordkeepers, and payroll providers, the IRS announced last week that it is giving more time to comply with mandatory Roth catch-up contributions under the SECURE Act 2.0. As you may know,...more
Section 401(k) Plans, Section 403(b) Plans and governmental Section 457(b) Plans generally permit employees to defer compensation on a pre-tax basis. These plans may also provide the opportunity for employees to defer...more
We have now had a couple of months to review and digest SECURE 2.0 (and its roughly 90 provisions impacting retirement plans). If plan sponsors haven’t done so already, it is time to roll up their sleeves and put a triage...more
...In a 1986 press conference, President Ronald Reagan infamously quipped: “the nine most terrifying words in the English language are: ‘I’m from the government, and I’m here to help.’” While legislation affecting retirement...more
SECURE 2.0 Act of 2022 (the “Act”) was signed into law by President Biden on December 29, 2022 (the date of enactment), as part of the larger government funding bill. The Act makes numerous changes affecting retirement plans....more