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06Nov

FLASHPOINT: IRS ANNOUNCES 2020 COST OF LIVING ADJUSTMENTS TO VARIOUS RETIREMENT PLAN LIMITS (AND SOME COMMENTS ON THE HARDSHIP REGULATIONS)

The IRS just released the cost of living adjustments for various retirement plan limitations that will take effect on January 1, 2020. Many of the limits will be increasing for 2020. The key limits that increased (shown below in bold italics) include the compensation that is taken into account for plan purposes, the salary deferral […]
03May

FLASHPOINT: IRS DETERMINATION LETTER PROGRAM EXPANDED … TO A LIMITED EXTENT

The IRS has expanded the availability of determination letters on individually designed plans in two circumstances: temporarily for “statutory hybrid plans” and permanently for merged plans. The availability of IRS approval of plan documents should give sponsors in these situations an opportunity to be reassured that their plan documents are “up to snuff.” The Determination […]
23Apr

FLASHPOINT: CORRECTIONS MADE EASIER: THE IRS EXPANDS THE SELF-CORRECTION PROGRAM

Last year, the IRS modified its correction programs for qualification failures (the “Employee Plans Compliance Resolution System” or “EPCRS”) to significantly increase the fees for taking part in the Voluntary Compliance Program (“VCP”). (See our previous FlashPoint on this subject.) Since that occurred, the retirement plan community has responded with demands that the IRS expand its […]
04Apr

FLASHPOINT: THINGS ARE HAPPENING … FINALLY!

After a period of national quiet in relation to retirement plans, several things have occurred recently that are worth discussing. Sorry that this is a longer newsletter than we like, but we wanted to give you quick feedback on what’s finally going on. California’s State-Mandated Retirement Program Survives Preemption Challenge One of the interesting trends […]
11Dec

FLASHPOINT: THE INS AND OUTS OF 403(B) DEFERRALS – THE IRS SOLVES THE PROBLEM

The IRS has provided important transition relief for many 403(b) plans struggling with an apparent change in IRS positions on a critical issue: how should 403(b) plans treat part-time employees who sometimes work more than 20 hours a week and sometimes work fewer? Recently issued Notice 2018-95 clarifies that what the IRS is calling “the […]
03Oct

FlashPoint: New EPCRS Procedure: Electronic Submission of VCP and Not A Whole Lot More

On September 28, 2018, the IRS issued Revenue Procedure 2018-52, the latest version of the Employee Plans Compliance Resolution System (“EPCRS”), the IRS’s comprehensive procedures for correcting retirement plan errors. Using this procedure, retirement plan sponsors may fix mistakes in their qualified plans, 403(b) plans, 403(a) retirement annuities, SEPs, and SIMPLEs. Although they are not […]
08Jan

FLASHPOINT: STICKING IT TO THE LITTLE MAN: WHY THE NEW IRS VCP FEES ARE BAD FOR SMALL BUSINESS, TPAS, AND RETIREMENT PLANS

  Forgive us if we don’t sing the praises of the Internal Revenue Service (“IRS”) for the most recent update to the Voluntary Correction Program (“VCP”) fee schedule.  A number of articles have been published since the release of Revenue Procedure (“Rev. Proc.”) 2018-4, expressing enthusiasm about the reduction of the fees for mega-corporations that […]
19Oct

FLASHPOINT – IRS ANNOUNCES 2018 COST OF LIVING ADJUSTMENTS

The IRS just released the cost of living adjustments for various retirement plan limitations that will take effect on January 1, 2018.  Many of the limits will be increasing for 2018. The Consumer Price Index, on which these limits are based, went up 2.2% during the prior twelve months.  The key limits that increased (shown […]