Reopening the Floodgates: IRS Announces Expanded Determination Letter Program

As we previously reported, the Internal Revenue Service (the “Service”) scaled back its determination letter program for individually designed retirement plans effective as of January 1, 2017. In the intervening years, the Service received a multitude of comments requesting the … Continue reading

Posted in Employee Benefits, Qualified Retirement Plans | Tagged , , , ,

Share this Article:

Seeing the Big Picture – How Proposed Health Reimbursement Arrangements Might Harmonize with Existing Law

On October 29, 2018, proposed regulations were published in the Federal Register that would permit employers to offer two new types of health reimbursement arrangements (“HRAs”) that align with the requirements of the Affordable Care Act (the “ACA”). The proposed … Continue reading

Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform | Tagged , , , , ,

Share this Article:

A Holiday Surprise – IRS Extends Certain ACA Reporting Deadlines and Transition Relief

The IRS delivered welcome news to employers preparing to meet the Affordable Care Act’s (“ACA”) information reporting deadlines in early 2019 for the 2018 calendar year. In Notice 2018-94 (the “Notice”), the IRS extended the employer’s deadline to furnish Forms … Continue reading

Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform | Tagged , , ,

Share this Article:

Making Limits Greater Again – IRS Issues Guidance on Cost of Living Adjustments

The IRS recently announced cost-of-living adjustments for 2019 in Notice 2018-83 and related guidance.  The key dollar limits for qualified retirement plans and health and welfare plans are noted below. Qualified Retirement Plan Dollar Limits   2018 2019 Limit on … Continue reading

Posted in Employee Benefits

Share this Article:

A New Perspective on Student Loan Repayment Benefits

On August 17, 2018, the Internal Revenue Service (the “Service”) published a Private Letter Ruling (the “PLR”) describing a unique student loan repayment program in the context of a qualified retirement plan. Proposed Student Loan Repayment Program As described in … Continue reading

Posted in Employee Benefits, Qualified Retirement Plans | Tagged , , , , ,

Share this Article:

The 95 Percent Test: Gearing up for Another Round of Employer Shared Responsibility Penalties

Late last year, the Internal Revenue Service (the “Service”) began enforcing penalties with respect to failures to comply with the employer shared responsibility provisions of Section 4980H of the Internal Revenue Code.  In the coming months, the Service is expected … Continue reading

Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform | Tagged , , , , ,

Share this Article:

Congress Eases Restrictions on Hardship Distributions

We previously reported on certain changes made to the hardship distribution rules for qualified retirement plans by the Tax Cuts and Jobs Act.  Since then, Congress has made additional and significant changes to those same hardship distribution rules by the … Continue reading

Posted in Employee Benefits, Qualified Retirement Plans | Tagged , , , ,

Share this Article:

IRS Announces Reduction in Family HSA Contribution Limit for 2018

In Revenue Procedure 2018-18, the Internal Revenue Service announced a reduction in the HSA contribution limit for family coverage in 2018 to $6,850 from $6,900.  The self-only HSA contribution limit for 2018 remains unchanged at $3,450. This change is a … Continue reading

Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform | Tagged , , , , , ,

Share this Article:

Approaching Deadlines for Affordable Care Act Reporting

As we recently reported in our “2017 End of the Year Plan Sponsor To Do List,” applicable large employers must continue to submit to the IRS and to employees information regarding offers of health coverage made to full-time employees in … Continue reading

Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform | Tagged , , , , , ,

Share this Article:

IRS Announces 2018 Cost of Living Adjustments

This post has been updated as of June 7, 2018, to reflect the revised maximum annual HSA contribution limit for family coverage set out in Revenue Procedures 2018-18 and 2018-27. The IRS recently announced cost-of-living adjustments for 2018 in Notice 2017-64 and … Continue reading

Posted in Employee Benefits, Health & Welfare Plans, Qualified Retirement Plans | Tagged , , , , , , , , , , , ,

Share this Article: