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In November 2023, the IRS issued proposed regulations addressing the SECURE 2.0 long-term part-time (LTPT) employee eligibility requirements applicable to 401(k) plans knowing that further guidance would be needed to explain...more
Nearly once a week, I receive a frantic call or email from a current or potential client who has received a proposed or final assessment from the IRS related to Affordable Care Act (“ACA”) reporting. So-called “Applicable...more
We are well into the Affordable Care Act (“ACA”) information reporting season. Forms 1095-B/1095-C must be provided to employees by March 1, 2024, and the deadline for electronic transmittal of Forms 1094-B/1094-C to the IRS...more
On November 24, 2023, the Internal Revenue Service (IRS) proposed long-awaited regulations providing guidance on the required coverage of long-term, part-time employees (LTPTEs) under the Setting Every Community Up for...more
The Setting Every Community Up for Retirement Enhancement Act (SECURE 1.0) requires plans to permit employees who work at least 500 hours but less than 1,000 hours in three consecutive 12-month periods to make elective...more
In this series of articles, we explore the implications of the long-term, part-time employee rules under the SECURE Act and SECURE 2.0 and the impact those rules have on employers and their workforces. Under the SECURE...more
In this series of articles, we explore the implications of the long-term, part-time employee rules under the SECURE Act and SECURE 2.0 and the impact those rules have on employers and their workforces. Following the...more
The employee benefits 2024 open enrollment season is quickly approaching and, with newly released IRS guidance, employers should be careful to ensure the health plan they offer employees is considered affordable. According to...more
In an increasingly competitive market for sophisticated and experienced professional and investment talent, family offices are seeking and applying new approaches to attract and retain top level executives. Transactional Tax...more
The Internal Revenue Service (IRS) has released Rev. Proc. 2022-34, which contains the inflation- adjusted amounts for 2023 that are used to determine whether employer-sponsored coverage is “affordable” for purposes of the...more
On September 29, 2021, Massachusetts Governor Charlie Baker signed into law an extension to the Massachusetts COVID-19 Emergency Paid Sick Leave (“EPSL”) program. As we wrote about in detail..., the EPSL program requires...more
On May 28, 2021, Massachusetts Governor Charlie Baker signed into law legislation requiring all Massachusetts employers to provide emergency paid sick leave to employees who are unable to work for certain reasons relating to...more
The American Rescue Plan Act of 2021 (ARPA) is the latest federal COVID-19 relief bill, which the President signed into law March 11, 2021. ARPA includes new COBRA continuation coverage election, notice, and subsidy...more
This month’s Friday Five discusses cases that address the meaning of “active, full-time employee,” whether remand is required where an improper standard of review was applied, the standard for capacity in reference to a...more
Disputes over the meaning of a word or phrase in an insured benefit plan almost always end up with the litigants feeling like they have gone through the looking glass to a place where the words you thought you understood all...more
Are Employees Receiving a Lavish Gift This Holiday Season or an Unintended Lump of Coal in Their Stockings? COVID-19 has forced many employers to make unanticipated changes to their workforce, with many retailers rolling...more
Employers with more than 500 employees nationally, and employers of healthcare-provider and emergency-responder employees previously exempted from Families First Coronavirus Response Act (FFCRA) requirements, must provide...more
Last week, California Governor Gavin Newsom signed an Executive Order mandating 80 hours of supplemental paid sick leave for COVID-19 related reasons be provided to “food sector workers” at private companies with 500 or more...more
It is hard to find a sector of the American workforce that has not been affected by the COVID-19 emergency. Employees are being asked to work from home if they are able, businesses are being forced to close, and employers are...more
Having recently helped a client determine if it employed on average more than 50 employees per month in a calendar year and therefore was an applicable large employer (“ALE”) subject to the Affordable Care Act (“ACA”) in the...more
In the growth of the gig economy, many employers are increasing the number of categories of their employees and associates. One challenge of the gig economy is determining when a worker qualifies as a full-time employee for...more
The IRS just announced an increase in the maximum permitted employee contribution percentages in 2019 for the purpose of determining the affordability of an employer's health plan under the Affordable Care Act (ACA)....more