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
IRS
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…
How the RMD Rules Are Like a New Puppy

On July 17, the Internal Revenue Service (IRS) issued an advance version of Notice 2023-54 (the Notice) which will include transition relief for plan administrators in connection with the change in the required beginning date for required minimum distributions (RMDs) under §401(a)(9) of the Internal Revenue Code (Code) under §107 of the Setting Every Community…
The IRS Starts the Summer with a Splash: New Guidance for Self-Correction
As discussed in an earlier blog post, the SECURE 2.0 Act of 2022 (the Act) expanded the Employee Plans Compliance Resolution System (EPCRS), a comprehensive IRS program for correcting common qualified retirement plan failures. Plan sponsors have three ways to correct mistakes under EPCRS: the self-correction program (SCP), the voluntary correction program…
IRS Gets Its Act Together For Forfeiture Rules
The February 24, 2023, issuance by the IRS of proposed regulations on the use of forfeitures in qualified retirement plans provides some welcome clarity, regulatory house cleaning, and relief for plan sponsors. With a proposed effective date of January 1, 2024, these regulations should prompt plan sponsors to review their plan language and procedures for…
The National Emergency Ends…. But Wait, There’s More!
We previously wrote about President Biden’s announcement to end the COVID-19 Public Health Emergency (PHE) and National Emergency (NE) periods on May 11, 2023, and the practical ramifications for employer group health plan sponsors as they administer COBRA, special enrollment, and other related deadlines tied to the end of the NE. As discussed, this action…
What Medical Expenses Qualify as Tax Deductible Under Section 213 Of The Internal Revenue Code?
On March 17, 2023, the Internal Revenue Service (IRS) issued new frequently asked questions (FAQs) addressing whether certain costs related to nutrition, wellness, and general health are medical expenses under Sec. 213 of the Internal Revenue Code (Code) that may be paid or reimbursed under an employee’s health savings account (HSA), health flexible spending arrangement…
SECURE 2.0 Series Part 1: More Roth, More Catch-Up, and Catch-Up As Roth
The SECURE 2.0 Act of 2022 (SECURE 2.0) contains several provisions that allow the federal government to have its cake (more tax dollars) and eat it too (more retirement savings, easing Social Security challenges). With SECURE 2.0, we find more Roth, more catch-up, and catch-up as Roth.
More Roth
Named after the late Delaware Senator…
2023 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 2023 (see IRS Notice 2022-55). Most notably, the limitation on annual salary deferrals into a 401(k) or 403(b) plan will increase from $20,500 to $22,500 and the dollar threshold…
4th Quarter 2022 Quick Hits for Plan Sponsors and Administrators
As we enter the fourth quarter of 2022, sponsors and administrators of employee benefit plans have a lot to juggle. From open enrollment and required notices to plan document deadlines, it is a busy time of year. Yet, there always seems to be something new to add to the mix. This year is no different. …