IRS guidance issued last week delays the implementation of mandatory Roth catch-up contributions. As outlined in our blog post earlier this year, SECURE 2.0 amended the catch-up contribution provisions of the Code. The Act provided that, beginning in 2024, individuals eligible to make catch-up contributions who made over $145,000 (indexed ...
Last week, the IRS announced it was increasing enforcement strategies aimed at Employee Stock Ownership Plans “ESOPs". The IRS stated this new focus on ESOPs is part of the effort to ensure tax laws are applied fairly and that high-income filers pay the taxes they owe. As part of this initiative, the IRS Commissioner commented that the IRS is ...
Last month the Sixth Circuit Court of Appeals upheld a lower court ruling that a company’s benefits committee did not properly delegate decision-making authority to its benefits department. As a result, the plaintiff’s appeal was reviewed under the de novo standard of review (which allows the court to conduct an independent analysis of ...
Errors in retirement plans happen even to the most well-intentioned plan sponsors. Several decades ago, the IRS published the first version of the Employee Plans Compliance Resolution Program (EPCRS), which outlines procedures by which plan sponsors can correct errors in their qualified retirement plans. Some of these errors could be ...