Employers that sponsor retirement plans continue to have a lot on their plate. With SECURE Act 2.0 requirements now in play, this legislation continues to add more and more to your (already) overflowing plate. However, as is...more
The IRS issued Notice 2024-2 (Notice), which provides guidance in a question and answer format concerning certain provisions of the SECURE 2.0 Act of 2022 (SECURE 2.0). The following is a brief overview of key provisions in...more
The IRS recently issued Notice 2024-02— dubbed the “Grab Bag Notice”— which addresses multiple provisions in SECURE 2.0. The guidance is 81 pages long, comes in the form of frequently asked questions and answers, and speaks...more
Earlier this year, the Internal Revenue Service (IRS) issued Notice 2022-23, which extended the deadline to make certain amendments pursuant to the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019,...more
The IRS has extended additional deadlines for required retirement plan amendments, similar to the extensions we discussed last month found here. Notice 2022-45 extends the deadline for amending qualified retirement plans to...more
The IRS on Aug. 3, 2022, issued Notice 2022-33, which extends the deadlines for qualified retirement plans, 403(b) plans and governmental retirement plans (including 457(b) plans) to adopt amendments reflecting certain...more
The IRS has issued a notice extending the deadline for retirement plan sponsors to make certain amendments required by recently passed legislation. Notice 2022-33 extends the deadline for amending qualified retirement plans...more
The IRS has given plan sponsors more time to adopt some – but apparently not all – retirement plan amendments reflecting law changes in the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the...more
Background (Effective elimination of determination letter process) - In Revenue Procedure 2016-37 the IRS eliminated the determination letter process for individually designed plans for all situations except initial plan...more
The Internal Revenue Service has announced that, in light of the COVID-19 pandemic, its March 31, 2020, deadline for remedial amendments to section 403(b) plans has been extended to June 30, 2020....more
Editor’s Note: A new rule from the IRS and other federal agencies could kick off the same kind of transformation for employer-sponsored health insurance that turned traditional pension plans into employee-directed 401(k)s. In...more
Newly published Revenue Procedure 2019-19 modifies and supersedes prior IRS guidance regarding the Employee Plans Compliance Resolution System (EPCRS) to allow plan sponsors to self-correct an expanded number of problems that...more
In Teufel v. Northern Trust Co. (April 11, 2018), the US Court of Appeals for the Seventh Circuit confirmed that a prospective change in the benefit formula for a defined benefit pension plan constituted neither an...more
I didn’t have such a great time at law school because I felt the administration and much of the faculty weren’t honest when it came to the study of law and more importantly, our job opportunities. There was one law professor...more
The IRS recently issued new mortality tables for 2018, which will likely increase pension funding liabilities for many plan sponsors. Plan sponsors should consider options to delay the use of the new mortality tables for...more
In Announcement 2017-11, the IRS relaxed standards for hardship distributions and loans from qualified retirement plans for those affected by Hurricane Harvey. This relief applies to employees or former employees and their...more
Eligible employers sponsoring Code Section 403(b) retirement plans have until March 31, 2020 to self-correct any defects as to the written form of those plans. In recently issued Revenue Procedure 2017-18, the IRS fixed March...more
The Internal Revenue Service (“IRS”) has modified procedures governing favorable determination letters for individually designed qualified retirement plans, including 401(k), profit sharing, defined benefit, and cash balance...more
The Department of Treasury and Internal Revenue Service issued final regulations addressing the minimum present value requirements for pension benefits payable partly as an annuity and partly in an accelerated form, usually a...more
The Treasury Department and the IRS recently issued final regulations (the “2015 Final Regulations”) relating to hybrid retirement plans, including cash balance pension plans. The 2015 Final Regulations provide...more
In recent guidance, the IRS surprised plan sponsors with its plan to prevent them from using one means of “de-risking” their defined benefit pension plans to reduce their pension plan liabilities. In Notice 2015-49, the IRS...more
The volatility and unpredictability of an employer's obligations under a defined benefit pension plan can have a significant impact on its bottom line. This is especially true of plans with liabilities for pension benefits...more
Plan sponsors that are scheduled to file determination letter applications with the IRS for their qualified retirement plans between February 1, 2015 and January 31, 2016, (Cycle E sponsors), should be aware that the IRS...more
In the U. S. Supreme Court's decision in United States v. Windsor (Windsor), the Court held that, for federal purposes, Section 3 of the Defense of Marriage Act (DOMA) is unconstitutional. Although the dispute in the Windsor...more