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The Internal Revenue Service gave retirement plan sponsors end-of-the-year gifts by providing guidance under twelve sections of the SECURE 2.0 Act of 2022 (“SECURE 2.0”). Although Notice 2024-2, released December 20, 2023 (the “Notice&rdquo...
The opportunity to self-correct mistakes in maintaining a retirement plan has been dramatically expanded by the SECURE 2.0 Act of 2022 (“SECURE 2.0”); see our February 10 blog post for details. However, IRS interim...
Under Section 404 of ERISA, plan fiduciaries must act for the exclusive benefit of plan participants and beneficiaries and use plan assets only to provide benefits and defray reasonable expenses of administering the plan...
We advised a major Massachusetts health system regarding the harmonization and rationalization of more than two dozen defined contribution plans with participant-directed investments, which were the combined legacy of several mergers by which the...
Newly issued IRS Proposed Regulations regarding the special eligibility and vesting requirements for long-term, part-time employees provide guidance that 401(k) plan sponsors have been waiting for since these requirements were established under SECURE 1.0...
We are often asked about the permissibility of excluding certain categories of employees from participating in an employer’s tax-qualified retirement plan. [1] This post provides a high-level summary of what is and is not...
We are well into the Affordable Care Act (“ACA”) information reporting season. Forms 1095-B/1095-C must be provided to employees by March 1, 2024, and the deadline for electronic transmittal of Forms 1094-B/1094-C to the...
This post summarizes provisions of SECURE 2.0 that retirement plans may need or want to implement for 2024. While no amendments are required for plans heading into 2024, plan operations may see some updates...
As part of the routine administration of employee benefit plans, shortly after the end of a calendar year, many transactions must be reported to the federal government (“information returns”) and participants (“payee statements”) using...