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
The IRS recently issued Notice 2024-2, which provides Q&A guidance on many provisions of the SECURE 2.0 Act, which had left employers and practitioners asking questions. We previously summarized several of the key changes...more
The IRS released long-awaited guidance under the SECURE 2.0 Act on December 20, 2023. Notice 2024-2 (Notice) provides clarification of various provisions, including several optional features that plan sponsors have been...more
Beginning this year, plan sponsors may increase their qualified plan’s mandatory cash-out limit from $5,000 to $7,000. The increase was enacted by SECURE 2.0, and applies to distributions made after December 31, 2023....more
The next installment of our updates on SECURE 2.0 is on another new in-service withdrawal option. SECURE 2.0 allows plan sponsors of defined contribution plans to amend their plans to allow plan participants who are victims...more
Our prior bulletin summarized the multitude of changes applicable to 401(k) and other retirement plans under the recently enacted “SECURE 2.0” law. This bulletin focuses on one of those changes and a potential reason for...more
Federal Bill C-228 (the Bill), new legislation intended to improve the protection of, and to extend the super-priority given to claims relating to, defined benefit pension plans in insolvency proceedings, completed third...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 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
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
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
Recently, the Sixth Circuit ruled in Hitchcock v. Cumberland University 403(b) Plan that pension plan participants are not required to exhaust their plan’s administrative remedies before pursuing claims alleging statutory...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