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Oct 31, 20193 min read
IRS Finalizes Regs to Changes to Hardship Distribution Rules
In the Bipartisan Budget Act passed in February 2018 (“Act”), Congress loosened certain restrictions on hardship distributions from...
275 views
Sep 30, 20196 min read
Don’t Get Bit by the COBRA
COBRA, or the Consolidated Omnibus Budget Reconciliation Act of 1985¹, provides for the temporary continuation of group health...
19 views
Sep 30, 20192 min read
DOL Proposes New Default Electronic Disclosure Safe Harbor
The Department of Labor (DOL) has issued proposed regulations providing a safe harbor under which employers would be able to ...
12 views
Aug 31, 20195 min read
Benefits Law in the Wild, Wild West
There are a lot of newcomers in town. The California legislature has been very busy lately creating new benefits law for...
55 views
Jul 31, 20195 min read
Multiple Employer Plans: The DOL Opens the Door (A Little)
In our newsletter last month, we described proposed regulations issued by the IRS that are intended to make it easier for plan sponsors...
301 views
Jul 31, 20197 min read
RMDs Are Not Just A Participant Headache
What is an RMD? A “required minimum distribution” (“RMD”) sounds simple in theory. It means that for all qualified plans and ...
498 views
Jul 1, 20191 min read
COBRA Compliance - Still Relevant in 2018!
Although COBRA has been in effect since 1985, employers still struggle with compliance, whether with everyday COBRA administration or ...
18 views
Jun 30, 20195 min read
Multiple Employer Plans and Saving the Barrel from the One Bad Apple
A multiple employer plan (“MEP”) is a tax qualified retirement plan that is maintained by two or more employers that are not part...
80 views
Jun 30, 20195 min read
California Enacts Individual Mandate and Premium Subsidies
With the Fifth Circuit Court of Appeals on the verge of determining the constitutionality and continued viability of the...
88 views
May 31, 20195 min read
The New CalSavers Law Takes Effect on July 1, 2019: What Employers Need to Do Now
The California Secure Choice Retirement Savings Trust Act (“CalSavers”) takes effect on July 1, 2019. Large employers that have at least...
59 views
Apr 30, 20193 min read
IRS Expands Self Correction Program in New EPCRS Procedure
The IRS has yet again updated the Employee Plans Compliance Resolution System (EPCRS), this time expanding the use of the Self ...
144 views
Apr 30, 20192 min read
What is a VCP?
A VCP is a submission to the IRS through its Voluntary Correction Program offered under the Employee Plans Compliance Resolution System...
78 views
Apr 30, 20194 min read
IRS Opens the Door to Determination Letter Applications for Merged and Cash Balance Individually...
IRS Opens the Door to Determination Letter Applications for Merged and Cash Balance Individually Designed Plans Revenue Procedure ...
14 views
Mar 31, 20195 min read
Self Directed IRAs: ERISA Issues Related to Non-Traditional Investments
The Initial Formation of a Self-Directed IRA Structure The landmark case of Swanson v. Commissioner, 106 T.C. 76 (1996) confirmed that an...
233 views
Mar 31, 20194 min read
Plan Amendment Deadlines and More
There is an old saying that goes: “Hindsight is 20/20,” but in the case of required plan amendments, that is not the case. Specific...
21 views
Feb 28, 20193 min read
Plan Termination Determination Letters: Form 5310 Pros and Cons
As of July 1, 2019, employers applying to the IRS for a favorable determination for a terminating plan will have to pay an ...
2,517 views
Feb 28, 20195 min read
A One-Time Offer from the IRS for 403(b) Plans Nears its Expiration Date
Albert Einstein theorized that because time is relative, a space traveler who leaves earth and travels near the speed of light ...
12 views
Jan 31, 20195 min read
Self-Directed IRAs: Your Personal Interests ns. Your IRA's Interests
IRA owners who self-direct their IRA’s investments serve in a fiduciary capacity to their IRA and are subject to a variety of...
21 views
Dec 31, 20186 min read
Proposed Rules to Expand HRAs Part 3: The Impact of Individual Coverage HRAs on PTC Eligibility (IRC
Proposed Rules to Expand HRAs Part 3: The Impact of Individual Coverage HRAs on PTC Eligibility (IRC Section 36B) and the Employer Shared...
57 views
Dec 31, 20185 min read
Unpacking the Settlor - Fiduciary "Two Hat" Principle
The difference between an employer’s “settlor” and “fiduciary” role with respect to its employee benefit plans, the so-called...
1,899 views
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