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Interim Guidance on Matching Qualified Student Loan Payments

Until recently, employer matching contributions under qualified plans were required to be conditioned solely upon employee contributions made to the plan. However, one of the many changes enacted by the Consolidated...more

Extended Relief for Required Minimum Distributions in 2024

Five years ago, the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”) made several significant changes to certain distributions required pursuant to Internal Revenue Code (“Code”) Section...more

Does Your Retirement Plan Need a 'PLESA'?

Pension-Linked Emergency Savings Accounts (“PLESAs”) are a special retirement plan feature created under SECURE ACT 2.0. PLESAs were first permitted to be made available to participants as of January 1, 2024. PLESAs, which...more

The End of the COVID-19 Emergency Declarations

Today marks the end of the COVID-19 public health emergency that first began on March 13, 2020. The end of the public health emergency has a wide range of implications for employer sponsored benefit plans. This alert...more

IRS Extends Deadline for Plan Amendments Under Certain Provisions of the CARES Act and the Relief Act

On September 26, 2022, the Internal Revenue Service issued Notice 2022-45, extending the deadline to amend eligible retirement plans (including nongovernmental qualified plans and 403(b) plans and individual retirement...more

The Reversal of Roe: Impact on Employer-sponsored Benefits post-Dobbs

On June 24, 2022, the Supreme Court of the United States (the “Court”) issued its opinion in Dobbs v. Jackson Women’s Health Organization, overturning the long-standing precedent of Roe v. Wade. In its 6-3 decision, the Court...more

SECURE Act Update: Lifetime Income Illustrations Implementing FAQs

The Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”) made sweeping changes to retirement plan rules. Section 203 of the SECURE Act requires that plan administrators provide participants in...more

Reminder: Notices Required For the End of COBRA Premium Assistance

The American Rescue Plan Act of 2021 (“ARPA”) made COBRA premium assistance available to certain assistance eligible individuals during the period from April 1, 2021 to September 30, 2021. ARPA also included new notice...more

IRS Publishes Detailed Guidance Relating to ARPA COBRA Premium Assistance

On May 18, 2021, the Internal Revenue Service (“IRS”) published Notice 2021-31 (the “IRS Notice”) containing detailed guidance relating to premium assistance for COBRA benefits under the American Rescue Plan Act of 2021...more

American Rescue Plan Act: New Guidance on COBRA Premium Assistance

The American Rescue Plan Act (“ARPA”) became law in March of this year. One of the many relief provisions included in ARPA is a temporary subsidy of COBRA continuation premiums for certain individuals, summarized in our...more

IRS Guidance: COVID-19 PPE May be Eligible to be Reimbursed from Health FSAs, HRAs, and HSAs

On March 26, 2021, the Internal Revenue Service (“IRS”) published Announcement 2021-7, which notifies taxpayers that certain amounts paid for personal protective equipment (such as masks, hand sanitizer, and sanitizing wipes)...more

American Rescue Plan Act: COBRA Premium Subsidies and Increased Limits for Dependent Care Benefits

On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”) which is another coronavirus stimulus package aimed at speeding up the United States’ recovery from the economic and health...more

DOL Issues Additional Guidance Regarding the Duration of Previously Announced Deadline Extensions

On February 26, 2021, the DOL issued guidance regarding the impact of that statutory limitation on the previously announced deadline extensions, in EBSA Disaster Relief Notice 2021-01. Disaster Relief Notice 2021-01, in...more

IRS Guidance on Additional Flexible Spending Account and Mid-Year Election Relief Under Cafeteria Plans in 2021 and 2020

On February 18, 2021, the IRS issued Notice 2021-15, which provides guidance with regard to a number of provisions of the temporary changes to the rules related to the operation of health and dependent care flexible spending...more

Stimulus Legislation Allows Temporary Changes to Health and Dependent Care Flexible Spending Account Plan Rules

On December 27, 2020, the latest of several COVID-19 relief packages became law, as part of the Consolidated Appropriations Act, 2021 (the “New Law”). One of the most notable benefits-related provisions in the New Law...more

SECURE Act Update: IRS Issues Guidance with Respect to Safe Harbor Plans

On December 9, 2020, the Internal Revenue Service (“IRS”) issued Notice 2020-86 which provides guidance relating to certain changes to the safe harbor rules that apply to 401(k) plans made by the Setting Every Community Up...more

SECURE Act Update: Nondiscrimination Testing Relief Related to Frozen or Closed Defined Benefit Plans and Changes to Permissible...

As part of our series of continuing updates on different aspects of The Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”) and related legislation that may impact (or provide opportunities...more

SECURE ACT Update: Lifetime Income Illustrations

The Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”), made sweeping changes to retirement plan rules. As part of our ongoing efforts to summarize key provisions of the SECURE Act that may...more

SECURE ACT Update: Coverage and Plan Participation for Long-Term Part-Time Employees

Signed into law on December 20, 2019 as part of the Further Consolidated Appropriations Act, 2020, The Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”), made sweeping changes to retirement...more

SECURE ACT Update: Changes to Safe Harbor Notice Rules, New Birth or Adoption Distributions, and Increased Penalties for Missed...

The Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”), made sweeping changes to retirement plan rules. As described in our prior alert, certain provisions took effect immediately and were...more

COVID-19 Update: New Retirement Plan Guidance on Electronic Notarization

COVID-19 has made traditional notarization, where the notary is in the same physical location as the signatory, a potentially hazardous and often undesirable requirement. Many states have reacted to this by permitting remote...more

COVID-19 Update: New Section 125 Cafeteria Plan Relief and Guidance

The Internal Revenue Service (“IRS”) recently issued Notice 2020-29 and Notice 2020-33 which allow employers to provide various new types of relief to employees participating in Section 125 cafeteria plans (including flexible...more

COVID-19 Update: IRS and DOL Extend COBRA and Other Benefit Plan Deadlines During the Pandemic Outbreak Period

On April 28, 2020, the Employee Benefits Security Administration, the Department of Labor, the Internal Revenue Service, and the Department of the Treasury (the “Agencies”) signed a joint notification of relief, which was...more

COVID-19: IRS Provides Additional Relief for Time-Sensitive Actions Relating to Employee Benefit Plans

Over the past few weeks, the Internal Revenue Service (“IRS”) has provided relief to taxpayers impacted by the COVID-19 pandemic, by extending the deadline for payment and filing of individual income tax returns from April...more

New York Statewide Paid Sick Leave is Here to Stay

Effective January 1, 2021, the majority of workers in New York will receive paid sick leave. On April 2, 2020, as part of New York’s budget approval process, the New York legislature and Governor Cuomo enacted a permanent...more

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