Seyfarth Synopsis: The IRS recently sought to reassure employers that they will not jeopardize their retirement plan’s tax qualified status if they permit employees who have a bona fide separation from service to take a distribution from their retirement plan, even if they are rehired shortly thereafter by the same employer. The reassurance comes in
One-Year Expiration of Outbreak Period: Pandemic Rages On, But It’s (Probably) Time to Pay Your COBRA Premiums
Seyfarth Synopsis: As you’ll recall, last Spring, the DOL and IRS issued guidelines providing relief from certain deadlines for employee benefit plans, retroactive to March 1, 2020 (i.e., the beginning of the COVID-19 national emergency declared by the President). The relief was issued pursuant to authority granted to the agencies under ERISA Section 518 and
Out for a Penny, Out for a Pound? IRS Provides Employees Opportunity to Cancel Non-Qualified Deferral Elections through Self-Certification
Seyfarth Synopsis: As Seyfarth has blogged about on multiple occasions [here and here], the CARES Act provides participants in tax-qualified retirement plans the opportunity to request distributions on a tax-favored basis by self-certifying that they have been adversely impacted by COVID-19. Seyfarth has also blogged about the IRS’s recent guidance on these distributions
Executive Compensation at Tax-Exempt Organizations Back in the Limelight – IRS Issues New Guidance
Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in excess of $1 million in annual compensation. The release of the proposed regulations comes at a time when executive pay, including at many tax-exempt
CARES Act Relief: Health and Welfare Plan Provisions
Seyfarth Synopsis: On March 27, 2020, the House of Representatives followed the Senate’s lead in voting overwhelmingly to pass the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The President signed the legislation into law shortly thereafter. This blog post highlights the health and welfare benefit provisions contained in the law. Click here to review
CARES Act Relief: Cash is Coming . . . with Freezes on Executive Pay, Buybacks and Dividends
Seyfarth Synopsis: After the Senate failed to secure the needed votes for a comprehensive coronavirus rescue package over the prior weekend, on Friday, Congress finally passed a $2 trillion package (the “CARES Act”) amidst classic drama between Republicans and Democrats in both houses. The President signed the legislation into law shortly thereafter. This blog post
Upcoming Webinar! Employee Benefits in a Time of COVID-19
On Monday, March 23, at 1:00 p.m. Central, Seyfarth partners Diane Dygert, Benjamin Conley, Jennifer Kraft, Kaley Ventura, Jake Downing, and Christina Cerasale are presenting a 1 hour CLE webinar, “Employee Benefits in a Time of COVID-19.”
Keep up with the latest developments and rapidly changing laws and regulations relating to COVID-19 and your benefit
Deadline is Approaching for Group Health Plan Service Agreement Updates
Seyfarth Synopsis: Recent changes to the federal rules governing confidentiality of substance use disorder (SUD) patient records may require updates to agreements between group health plans and their third-party vendors. Group health plans may be caught up in the changes if they wind up in possession of certain SUD patient records and disclose those records