The IRS recently provided some welcome relief in the form of extended amendment deadlines for sponsors of qualified retirement plans (including collectively bargained plans). Notice 2022-33 extends the deadline for adopting amendments required by the Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE Act”) and the Bipartisan American Miners Act of 2019 […]
AM
We previously reported on the Bipartisan Budget Act (the “Budget Act”) hardship distribution rule changes for qualified retirement plans. On September 23, 2019, the IRS issued final regulations implementing certain statutory changes to the hardship distributions rules, including those required by the Budget Act. The final regulations closely track the proposed regulations issued in November […]
RJ
The IRS recently issued its latest version of the Employee Plans Compliance Resolution System (“EPCRS”) in Rev. Proc. 2019-19. The EPCRS is the IRS program that assists employers in correcting both operational and document failures with respect to qualified retirement plans. There are several welcome changes to the new EPCRS, including: Certain plan loan failures […]
MS
In a previous blog, we discussed the IRS’ elimination of its five year staggered determination letter cycle for individually designed plans. The IRS recently provided guidance to help sponsors of individually designed plans keep their plans in compliance with applicable law. Notice 2016-80 contains the first Required Amendments List (the “RA List”) for individually designed […]
AM