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IRS reminds employers that implementing certain optional retirement plan provisions of SECURE 2.0 affect Form W‑2 and Form 1099‑R reporting starting in 2023 - The IRS recently issued Fact Sheet 2024‑18 to highlight how...more
On December 20, 2023, the IRS issued Notice 2024-2, which provides question-and-answer guidance on various aspects of the SECURE 2.0 Act. This post focuses on the ability to make employer contributions (match or nonelective)...more
The Internal Revenue Service and U.S. Department of Labor recently issued guidance on various aspects of the Consolidated Appropriations Act of 2023, commonly referred to as SECURE 2.0. Below is a summary of key provisions...more
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
Seyfarth Synopsis: Under Section 604 of Secure 2.0, sponsors of 401(k), 403(b) and governmental plans may allow employees to designate employer match (including match on student loan repayments) or nonelective contributions...more
As 2023 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. Part 1 covered health and welfare plan...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
The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more
While most of the country was gearing up for the U.S. Open, retirement plan sponsors and service providers collectively celebrated a big win on August 25 when the IRS delayed the new Roth catch-up rule until January 1, 2026. ...more
A recent announcement from the IRS (IR-2023-62) modifies and clarifies Roth IRA catch-up payment requirements for contributors who are aged 50 or older. IR-2023-62 delayed mandatory Roth IRA catch-up payments for high income...more
To the relief of plan sponsors everywhere, the Internal Revenue Service (IRS) recently issued Notice 2023-62, which provides guidance on the requirements of Section 603 of the SECURE Act 2.0 of 2022 relating to catch-up...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
IRS guidance issued last week delays the implementation of mandatory Roth catch-up contributions. As outlined in our blog post earlier this year, SECURE 2.0 amended the catch-up contribution provisions of the Code....more
On August 25, 2023, the IRS issued IRS Notice 2023-62, providing much needed relief for employers who have been struggling to implement Section 603 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”), which requires high income...more
The Internal Revenue Service (“IRS”) provided welcome relief for administrators of plans offering catch-up contributions. Notice 2023-62, issued on August 25, essentially delays the effective date of a provision under the...more
Late last week, the Internal Revenue Service (IRS) issued guidance on Section 603 of the SECURE 2.0 Act with respect to catch-up contributions. The guidance includes a two-year administrative transition period – until 2026 –...more
On Friday, Aug. 25, 2023, the IRS announced a two-year reprieve for employers on the implementation of SECURE 2.0's requirement that catch-up contributions made by higher-income participants be designated as after-tax Roth...more
Section 603 of the SECURE 2.0 Act of 2022 (SECURE 2.0) requires that catch-up contributions for individuals whose wages exceed $145,000 are subject to mandatory Roth tax treatment effective as of January 1, 2024. Due to the...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
On August 25, the Internal Revenue Service issued Notice 2023-62 (the Notice) delaying implementation of a provision of the SECURE 2.0 Act of 2022 that, commencing in 2024, would have required catch-up contributions by...more
On August 25, 2023, the Internal Revenue Service announced a two-year delay in implementing changes to the catch-up retirement contributions of certain taxpayers....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
The Internal Revenue Service (IRS) has announced a two-year administrative transition period that delays until 2026 the new rule that catch-up contributions made by certain higher‑income participants in 401(k), 403(b), and...more