Seyfarth Synopsis: As previously reported here, on December 20, 2023, the IRS issued Notice 2024-2 (the “Notice”) providing guidance on several outstanding questions related to provisions under SECURE 2.0. This blog post summarizes the guidance under the Notice for in-service distributions to terminally ill employees that qualify for a waiver from the 10%
Liz Deckman
The IRS’s Grab Bag of SECURE 2.0 Guidance is Here!
Seyfarth Synopsis: Adding to the holiday joy of employee benefits practitioners nationwide, yesterday the IRS issued guidance on several outstanding questions related to SECURE 2.0. At this time of year, we are especially thankful that the guidance was issued on a day other than the day before or following a national holiday.
The so-called “grab…
The Benefits of Flying into SFO; Employees Have Free Family Health Insurance – For Now
Seyfarth Synopsis: In August, the Ninth Circuit Court of Appeals revived a challenge by Airlines for America (“A4A”), to San Francisco’s Healthy Airport Ordinance (the “Ordinance”), which requires airlines that use the San Francisco International Airport, which the City runs, to provide enhanced health plan benefits to the airlines’ employees and their dependents. A4A, an…
A Reminder – Washington Cares Fund Premium Payments To Begin July 2023
Seyfarth Synopsis: As a reminder to companies with workers in Washington State, payroll tax withholding under the Washington State Long Term Care Act will begin on July 1, 2023, unless an employee qualifies for an exemption. Companies with employees in Washington will need to be ready to withhold the payroll tax and keep track of…
Time is On Our Side 2.0; More Time to Amend for CARES Act Optional Amendments
Seyfarth Synopsys: On September 26, 2022, the IRS issued Notice 2022-45, extending the deadline for amending retirement plans and individual retirement accounts (“IRAs”) for optional changes under the CARES Act.
As we discussed in our prior blog post [here], on August 3, 2022. the IRS issued Notice 2022-33, extending the deadlines for amending…
Class Action Lawsuit Filed Against Washington State’s Long Term Cares Act – Dismissed!
A federal judge has dismissed a class action lawsuit that challenged the Washington Long-Term Cares Act (“Cares Act”), ruling that because the Cares Act is not established or maintained by an employer and/or employee organization, it is not an employee benefit plan and therefore not governed or preempted by ERISA. The Court also held that…
SECURE 2.0: Here We Go Again
Seyfarth Synopsis: The SECURE Act, passed just before the onset of the COVID-19 pandemic at the end of 2019, significantly altered the retirement plan landscape. For a reminder on how the SECURE Act changed the retirement landscape click here and here. In 2021, another bill, Securing a Strong Retirement Act of 2021, was considered…
It’s Official: Governor Inslee Signs Bills to Delay and Modify Washington’s Long Term Care Act
Seyfarth Synopsis: After announcing a moratorium on the State’s collection of the Washington Cares Fund long term care (“LTC”) payroll tax from employers on December 17, 2021, Governor Inslee signed into law House Bills 1732 and 1733 on Thursday. The bills formally delay the program until July 1, 2023, and implement several changes that are…
Washington State LTC Act; State Not Collecting Payroll Tax from Employers, but Employers to Collect Tax from Employees?
Seyfarth Synopsis: Although Washington State Governor, Jay Inslee, has announced a moratorium on the State’s collection of the Washington Cares Fund long term care (“LTC”) payroll tax from employers without penalty, last Thursday he backtracked somewhat, saying that he does not have the authority to allow employers not to collect the tax from employees…
An Early Holiday Present for Washington State Employers; Long Term Care Act Payroll Tax Moratorium Announced
Seyfarth Synopsis: On Friday, Washington State Governor, Jay Inslee, announced a moratorium on the State’s collection of the Washington Cares Fund long term care (“LTC”) payroll tax. The Washington Cares Fund was originally set to begin collecting taxes in January 2022 to help pay for the LTC expenses of the State’s residents. For more information…