- Generally, plan sponsors should be prepared to implement the Roth catch-up rule for taxable years beginning after December 31, 2025 (i.e., January 1, 2026, for calendar year plans). This will require coordination with ERISA counsel, the company’s payroll provider, and the plan’s recordkeeper and third-party administrator.
- Be prepared to discover mistakes and correct them
Missing Participants – New State Unclaimed Property Fund Option for Small Balances
Exciting Update: Self-Correction for Delinquent Contributions Now Possible Under the DOL’s VFCP
2025 Cost of Living Adjustments for Retirement Plans
The Internal Revenue Service recently announced its cost-of-living adjustments applicable to dollar limitations on benefits and contributions for retirement plans generally effective for Tax Year 2025 (see IRS Notice 2024-80). Most notably, the limitation on annual salary deferrals into a 401(k) or 403(b) plan will increase to $23,500, and the dollar threshold for…
New Guidance: Emergency Personal Expense and Domestic Abuse Victim Distributions
Of interest to 401(k) plan sponsors and administrators, the IRS recently issued Notice 2024-55, providing guidance on SECURE 2.0’s new exceptions—effective January 1, 2024—to the additional 10% tax on early qualified retirement plan distributions for emergency personal expenses and victims of domestic abuse. Both types of distributions are optional and may be adopted through…
Use of Plan Forfeitures Not the Slam Dunk It Used to Be
A recent rash of class action lawsuits in California claim that using forfeitures to reduce future employer contributions to tax-qualified retirement plans runs afoul of the Employee Retirement Income Security Act (ERISA). These cases have continued to advance despite their central claim seeming to contradict long-standing Internal Revenue Service (IRS) guidance for the permitted use…
Automatic Enrollment: This Is The Way
Thanks to SECURE Act 2.0, newly established 401(k) and 403(b) plans must now have an automatic enrollment. The SECURE Act 2.0 was passed in December 2022 and made sweeping changes to retirement plan regulations. We discuss many of those changes in our SECURE Act 2.0 blog series.
Plans with an automatic enrollment feature immediately…
The DOL Issues New Guidance on PLESA
The SECURE 2.0 Act of 2022 had many retirement plan provisions, including the pension-linked emergency savings account (PLESA) that lets workers contribute money to an account in a defined contribution plan that can be used to cover unforeseen financial hardships. In consultation with the Treasury Department and the IRS, the DOL recently issued guidance regarding…
2024 Cost of Living Adjustments for Retirement Plans
The Internal Revenue Service recently announced its cost-of-living adjustments applicable to dollar limitations on benefits and contributions for retirement plans generally effective for Tax Year 2024 (see IRS Notice 2023-75). Most notably, the limitation on annual salary deferrals into a 401(k) or 403(b) plan will increase to $23,000, and the dollar threshold for highly…
You Need to Calm Down
On August 9, the IRS issued a news release, IR-2023-144, warning taxpayers and advisors of “numerous compliance issues” with ESOPs, such as “valuation issues with employee stock,” “prohibited allocation of shares to disqualified persons,” “failure to follow tax law requirements for ESOP loans causing the loan to be a prohibited transaction” and “promoted arrangements…