This post has been updated as of March 4, 2025.
Seyfarth Synopsis: On December 17, 2024,
the House Ways and Means Committee and the Senate Finance Committee presented
two bills – the Paperwork Burden Reduction Act (HR 3797) and the Employer Reporting Improvement Act (HR 3801) – to President Biden, which he signed into
Seyfarth Synopsis: On August 19, 2024, the IRS issued Notice 2024-63 (the “Notice”) providing guidance for plan sponsors that wish to provide matching contributions based on eligible student loan repayments made by participants, rather than based only on elective deferrals, pursuant to the SECURE 2.0 Act of 2022. This post summarizes guidance under the Notice.
Section 110 of the SECURE 2.0 Act of 2022 codified rules that permitted plan sponsors to make a matching contribution to a 401(k), 403(b), SIMPLE or governmental 457(b) plan based on a participant’s “qualified student loan payment,” in addition to matching contributions on a participant’s elective deferral contribution to the plan. These rules already took effect this year, and the IRS has now issued welcome guidance on how this provision should be implemented.Continue Reading Major SECURE 2.0 Guidance Issued: Extra Credit for Repaying Qualified Student Loans
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%
The Internal Revenue Code provides significant tax benefits for both employers and employees participating in a 401(k) or 403(b) plan. In exchange for these tax benefits, the plan must satisfy a litany of requirements, notably that a plan be administered in accordance with its plan document. Failure to do so could result in the plan’s
Seyfarth Synopsis: Recently the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued regulations (the “Final Regulations”) which finalized previously proposed relief for furnishing Forms 1095-B and 1095-C to individuals. Notably, the Final Regulations provide a permanent 30-day extension to the due date for furnishing Form 1095-C to individuals. This extension was previously granted in the 2021 final instructions for completing Forms 1094-C and 1095-C for 2021 (see our blog here) issued in December 2021.Continue Reading Permanent Extension to the ACA Reporting Deadline
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
Seyfarth Synopsis: The IRS has released final instructions for completing Forms 1094-C and 1095-C for 2021. Notably the instructions provide that the due date for furnishing Form 1095-C to individuals is extended to March 2, 2022. As expected, the instructions no longer offer penalty relief for good faith incorrect or incomplete filings and Form
Seyfarth Synopsis: The IRS just announced the 2022 annual limits that apply to tax-qualified plans. After minimal changes last year, there are several updates to the limits that employers should be aware of. Employers maintaining tax-qualified retirement plans will need to make sure their plans’ administrative procedures are adjusted accordingly.
In Notice 2021-61, the IRS
Seyfarth Synopsis: On June 25, 2021, the IRS released two information letters related to health savings accounts (“HSAs”) and high deductible health plans (“HDHPs”) addressing: (i) correction of excess employer contributions to an HSA, and (ii) how coupons, such as prescription drug coupons, apply toward the HDHP minimum annual deductible and what benefits can be
Seyfarth Synopsis: The SECURE Act, passed at the end of 2019, significantly altered the retirement landscape. Now, proposed legislation, “SECURE Act 2.0,” sets out to make even more changes. As before, several of the proposed provisions will require employers to closely consider the new rules. For newly established plans, there will be requirements that did