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10Sep

FLASHPOINT: ALL THE GUIDANCE THAT’S FIT TO PRINT: GIFTS FROM THE DOL AND IRS (GEE, WE DIDN’T GET THEM ANYTHING!)

In the last few weeks, the U.S. Department of Labor (“DOL”) and Internal Revenue Service (“IRS”) have published a number of key items of guidance.  Ranging from Pooled Plan Provider (“PPP”) registrations and lifetime income illustrations to rollover rules for qualified plan loan offsets, the materials are vast and welcome by many in this industry. […]
18Aug

FERENCZY FLASHPOINT: USER FEES GOING UP AND CARES UPDATE

Updated User Fees for IRS Filings The IRS just issued the user fees for 2021 in Announcement 2020-14.  Unlike in 2018, when the IRS increased user fees overnight with no advance notice (yes, we hold a grudge), the IRS is letting us know several months in advance so that we can take some preemptive action […]
30Jun

FLASHPOINT: IRS STILL CARES SUSPENSION OR REDUCTION OF SAFE HARBOR CONTRIBUTIONS FOR 2020

In Notice 2020-52 (the “Notice”), issued on June 29, 2020, the IRS continues providing relief for employers during the COVID pandemic.  In particular, the Notice permits employers to suspend or reduce safe harbor contributions in 401(k) and 403(b) plans after March 13, 2020, for the balance of the year, regardless of whether the employer is […]
24Jun

FLASHPOINT: WAIT! THERE’S MORE! IRS ISSUES CARES RMD GUIDANCE

Under the heading of “No Good Deed Goes Unpunished,” we were just patting ourselves on the back for getting out the Notice 2020-50 FlashPoint so quickly when the IRS laughed in our face.  A mere two working days later, on June 23, 2020, the IRS issued Notice 2020-51 (the “Notice”), providing guidance in relation to […]
22Jun

FlashPoint: The IRS CARES! (Who’d Have Thunk?) Expanded List of Qualified Individuals and More Info!

On Friday, June 19, 2020, the IRS issued Notice 2020-50 (the “Notice”), which provides expanded guidance on Coronavirus-Related Distributions (“CRDs”) and the CARES participant loan rules. Expansion of Definition of Qualified Individual You may recall from the prior Flash, “Coronavirus Relief from Congress – The CARES Act,” that the following individuals were considered to be […]
02Jun

FLASHPOINT: RIDERS, FEET ON THE PEDALS! DC TRICYCLE RESTATEMENTS ARE ABOUT TO BEGIN!

The IRS has just announced (Announcement 2020-07) the key details for the third cycle (“Tricycle”) of restatements for preapproved defined contribution plans. Document providers submitted their draft documents in 2018, and the IRS anticipates completing its review and issuing opinion letters for these preapproved plans on June 30, 2020. This will begin the formal restatement […]
05May

FLASHPOINT: DEALING WITH THE PANDEMIC: IRS AND DOL AUTHORIZED DELAYS

Both the Internal Revenue Service (IRS) and the Employee Benefits Security Administration (EBSA) (the section of the U.S. Department of Labor (DOL) with jurisdiction over employee benefit plans) recently issued guidance delaying certain plan-related deadlines while the COVID pandemic is ongoing.  Some of these delays apply to the participants, generally giving them more time to […]
27Mar

FLASHPOINT: CORONAVIRUS RELIEF FROM CONGRESS – THE CARES ACT

On Friday, March 27, 2020, the House passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), a massive relief bill for those suffering as a result of the Coronavirus pandemic, which was passed earlier in the week by the Senate.  As the bill is the result of significant negotiations between both parties and […]
02Mar

FLASHPOINT: IRS REPRESENTATIVES SAY NO IMMINENT VCP CHANGES

IRS representatives attending the TE/GE Council meetings this week have confirmed that there is no significant action being taken by the IRS at this time to modify the Voluntary Correction Program (VCP) program. On February 25, 2020, the American Retirement Association (ARA) reported in its online newsletters that, according to an IRS whistleblower, the IRS […]