June 4, 2018

H&W: ACA Play or Pay Penalty Notification and Response Process

In our earlier blog, we discussed how the IRS would be notifying Applicable Large Employers (“ALE”) when they are identified as potentially liable for an employer shared responsibility payment (“ESRP”).  Specifically, we discussed Letter 226J which the IRS will send to ALEs notifying them of a proposed penalty being assessed against them because one of… Continue Reading

401(k): IRS Revamps Plan Document Approval Process

As you are probably aware, effective January 1, 2017, the IRS made sweeping changes to its rulings and determination letter program for qualified plans. The most striking change was the elimination of the prior five-year cycle for submitting determination letter applications for individually designed plans. In addition, changes were made to the process for obtaining… Continue Reading

May 30, 2018

401(k): IRS Considers Expanding Determination Letter Program in 2019 for Certain Individually Designed Plans

Background In 2017, the IRS made sweeping changes to its rulings and determination letter program for qualified plans. The most striking change was the elimination of the prior five-year cycle for submitting determination letter applications for individually designed plans, although the process for obtaining opinion letters for preapproved plans was also revamped. Following the 2017… Continue Reading

May 23, 2018

401(k): What’s in a Name? IRS Changes Terminology for Preapproved Plans

In 2017, the IRS made sweeping changes to its rulings and determination letter program for qualified plans. The most striking change was the elimination of the prior five-year cycle for submitting determination letter applications for individually designed plans. Similarly, the process for obtaining opinion letters for preapproved plans was also revamped. One change that has… Continue Reading

May 21, 2018

401(k): Let Us Observe a Moment of Silence for the Fiduciary Rule

On May 7, 2018, the U.S. Department of Labor (“DOL”)’s controversial “Fiduciary Rule” – long the bane of the ERISA financial services industry – was taken off life support, following a lengthy series of blows. The latest, and most lethal, setback came when, on March 15, 2018, the U.S. Court of Appeals for the Fifth… Continue Reading

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