On July 26, 2021, the U.S. Internal Revenue Service (“IRS”) issued Notice 2021-46, providing additional guidance on the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) and premium assistance and tax credit provisions of the American Rescue Plan Act of 2021 (“ARPA”). As described in our Legal Update , ARPA requires employers to cover
How to Sign Your Life Away… Electronically
Seyfarth Synopsis: Electronic signatures may be the wave of the future for the IRS, and are more necessary now as a result of the remote work environment. The IRS issued some recent guidance, allowing two authorization forms (Forms 2848 and 8821) to be signed electronically. While this guidance is a welcome step in the direction
Happy New Year! The IRS Grants Permission to Celebrate New Year’s Eve
Seyfarth Synopsis: The IRS has announced that the due date for contributions to a single-employer defined benefit pension plan due in 2020, previously extended to January 1, 2021 by the CARES Act, will be considered timely if made no later than January 4, 2021.
Under the funding rules for qualified defined benefit pension plans, plan
Whistleblowing Hits Employee Benefits World
Seyfarth Synopsis: Recently a “whistleblower” leaked that the IRS had internally announced an upcoming modification to the very popular voluntary correction program (“VCP”) that would have been a significant disincentive for plan sponsors to use the VCP to report and correct plan disqualification errors. The leak went viral and sent benefits counsel and other retirement
You Can Save More in Your 401(k) in 2020
By Sarah Touzalin and Richard G. Schwartz
Seyfarth Synopsis: Many of the limitations that apply to tax-qualified plans, including 401(k) plans, are subject to cost-of-living increases. The IRS just announced the 2020 limits. 401(k) plan contribution limits are increasing, so check your elections starting in 2020. Employers maintaining tax-qualified retirement plans will need to make
The Check is in the Mail—Or Not
By Diane Dygert and Richard Schwartz
Seyfarth Synopsis: The IRS recently issued somewhat helpful guidance to plan administrators on what to do about the constant problem of uncashed benefit checks from qualified retirement plans. The initial excitement upon hearing the news, however, was quickly met with disappointment as the realization set in that the