On July 16, 2021, IRS issued Revenue Procedure 2021-30 to update the Employee Plans Compliance Resolutions System (the “EPCRS”). The update in part expands the opportunities for plan sponsors to self-correct failures under the EPCRS by: (1) extending the self-correction period from two to three years; (2) expanding the ability for plan sponsors to correct […]
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On December 20, 2019, President Trump signed the Further Consolidated Appropriations Act, 2020, a spending bill that includes the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). The SECURE Act initially passed the House in May, as discussed in our S&W Benefits Blog “The SECURE Act – A Primer on […]
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It’s that time of year when boys and girls start making their lists for the holidays, but we in the employee benefits world make a very different kind of list. In the rapidly changing world of employee benefits and executive compensation law, checklists can be particularly helpful to make sure important issues do not fall […]
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In Announcement 2015-19, the IRS announced the elimination of the five year remedial amendment cycle for individually designed retirement plans effective as of January 1, 2017. This means that after January 1, 2017, individually designed retirement plans will no longer be eligible to receive favorable determination letters every five years. The Announcement leaves the current […]
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In its April 1, 2015 Employee Plans News, the IRS stated that defined contribution plan sponsors must maintain hardship distribution records and that plan sponsors cannot rely on electronic participant self-certification for hardship distributions. The IRS indicated that plan sponsors should keep the following: Documentation of the hardship request, review and approval; Financial information that […]
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The IRS recently announced changes that make it significantly easier to correct employee deferral mistakes (also known as elective deferrals) in qualified retirement plans. The changes make modifications to the IRS’ Employee Plans Compliance Resolution System (“EPCRS”), which is the IRS’ comprehensive correction program for qualified retirement plans. Automatic Enrollment Correction Relief If a qualified […]
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The IRS recently announced cost of living adjustments for 2015. The key dollar amounts for retirement plans (compared to the 2014 dollar limits) are noted below. Maximum Qualified Retirement Plan Dollar Limits 2015 2014 Limit on Section 401(k) deferrals (Section 402(g)) $18,000 $17,500 Dollar limitation for catch-up contributions (Section 414(v)(2)(B)(i)) $6,000 $5,500 […]
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The abrupt departure of Bill Gross from PIMCO leaves many investors pondering their next move. Should an investor stay the course and see how PIMCO’s new investment team performs? Should an investor leave and follow Mr. Gross to Janus Funds? Should an investor rush to find a new bond fund manager? These questions are particularly important […]
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The IRS recently issued guidance on the use of longevity annuities in defined contribution plans and IRAs. These longevity annuities are known as “qualified longevity annuity contracts” or “QLACs.” A QLAC is a deferred annuity that begins at a specified age, but not later than age 85. This type of annuity allows individuals to have […]
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Many employers adopt defined contribution retirement plans that have been pre-approved by the IRS. Plan sponsors of pre-approved plans submit the plans to the IRS to obtain approval of whether the form of the plan meets the requirements of Internal Revenue Code Section 401. These pre-approved plans are often referred to as “volume submitter plans” […]
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