Recent Posts
Blog Post
02/09/2021
By Sarah Lockwood Church and Andrew J. Daly and Dasha G. Brockmeyer

Reductions in force during 2020 that resulted in significant turnover in active retirement plan participation could constitute a partial plan termination that requires 100% vesting of affected employees.  The Consolidated Appropriations Act of 2021 temporarily modifies prior IRS guidance on how to make a partial termination determination.  This new, temporary statutory provision looks solely at whether the number of active plan participants on March 31, 2021 is at least 80% of the number of active plan participants on March 13, 2020. Click

Blog Post
01/15/2021
By Sarah Lockwood Church and Dasha G. Brockmeyer and Paul A. Kasicky

If you have part-time employees and sponsor a 401(k) plan, the SECURE Act requires your plan to permit part-time employees who complete at least 500 hours of service over three continuous 12-month periods (and satisfy any eligibility age requirement) to make elective deferral contributions. Periods of service before January 1, 2021 are not counted to determine participation eligibility, and the plan does not have to provide other employer contributions to these “long-service, part-time employees.”

Blog Post
12/29/2020
By Andrew J. Daly

The coronavirus relief and government funding bill enacted on December 27, 2020, includes many tax provisions among its more than 5,500 pages. This alert summarizes the key tax credits available to support employers through the ongoing coronavirus pandemic.

 

Blog Post
07/27/2020
By Sarah Lockwood Church and Paul A. Kasicky

Tax rules require retirement plan participants to start their benefits by a specific date. Generally, this date is based on the age of the participant and whether the participant is still working after reaching that age. Before the SECURE Act, these distributions – called Required Minimum Distributions or RMDs – had to start by a “Required Beginning Date” which was April 1 of the calendar year following the date the participant reaches age 70-1/2, or, if later, April 1 of the calendar year after the participant’s employment terminates.

Blog Post
07/16/2020
By Sarah Lockwood Church and Andrew J. Daly and Dasha G. Brockmeyer

Plan sponsors of safe-harbor 401(k) plans find it difficult to satisfy the conditions permitting them to amend safe-harbor plans mid-year to reduce or eliminate the employer safe harbor nonelective or matching contribution. They either had to reserve the right to amend the plan in the annual safe harbor notice provided to plan participants or be operating at an economic loss. In addition, in order to make any change to a safe harbor plan mid-year, participants had to be given an advance 30-day notice of the amendment.

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