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A Holiday Surprise – IRS Extends Certain ACA Reporting Deadlines and Transition Relief

The IRS delivered welcome news to employers preparing to meet the Affordable Care Act’s (“ACA”) information reporting deadlines in early 2019 for the 2018 calendar year. In Notice 2018-94 (the “Notice”), the IRS extended the employer’s deadline to furnish Forms 1095-B and 1095-C to employees. The new deadlines are provided below. Original Distribution Deadline Extended […]

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Making Limits Greater Again – IRS Issues Guidance on Cost of Living Adjustments

The IRS recently announced cost-of-living adjustments for 2019 in Notice 2018-83 and related guidance.  The key dollar limits for qualified retirement plans and health and welfare plans are noted below. Qualified Retirement Plan Dollar Limits   2018 2019 Limit on Section 401(k) deferrals (Section 402(g)) $18,500 $19,000 Dollar limitation for catch-up contributions (Section 414(v)(2)(B)(i)) $6,000 […]

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A New Perspective on Student Loan Repayment Benefits

On August 17, 2018, the Internal Revenue Service (the “Service”) published a Private Letter Ruling (the “PLR”) describing a unique student loan repayment program in the context of a qualified retirement plan. Proposed Student Loan Repayment Program As described in the PLR, an Employer sponsors a Section 401(k) defined contribution plan that permits elective deferrals. […]

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The 95 Percent Test: Gearing up for Another Round of Employer Shared Responsibility Penalties

Late last year, the Internal Revenue Service (the “Service”) began enforcing penalties with respect to failures to comply with the employer shared responsibility provisions of Section 4980H of the Internal Revenue Code.  In the coming months, the Service is expected to begin assessing penalties with respect to such failures occurring in calendar year 2016.  These […]

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Congress Eases Restrictions on Hardship Distributions

We previously reported on certain changes made to the hardship distribution rules for qualified retirement plans by the Tax Cuts and Jobs Act.  Since then, Congress has made additional and significant changes to those same hardship distribution rules by the passage of the Bipartisan Budget Act (the “BBA”).  The BBA loosens various restrictions on a […]

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IRS Announces Reduction in Family HSA Contribution Limit for 2018

In Revenue Procedure 2018-18, the Internal Revenue Service announced a reduction in the HSA contribution limit for family coverage in 2018 to $6,850 from $6,900.  The self-only HSA contribution limit for 2018 remains unchanged at $3,450. This change is a technical result of the Tax Cuts and Jobs Act, which adjusted the method for calculating […]

Approaching Deadlines for Affordable Care Act Reporting

As we recently reported in our “2017 End of the Year Plan Sponsor To Do List,” applicable large employers must continue to submit to the IRS and to employees information regarding offers of health coverage made to full-time employees in 2017. The IRS recently published Notice 2018-06 (the “Notice”), which contains some relief with respect […]

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IRS Announces 2018 Cost of Living Adjustments

This post has been updated as of June 7, 2018, to reflect the revised maximum annual HSA contribution limit for family coverage set out in Revenue Procedures 2018-18 and 2018-27. The IRS recently announced cost-of-living adjustments for 2018 in Notice 2017-64 and related guidance.  The key dollar limits for qualified retirement plans and health and welfare plans […]

Transgender Benefits Revisited?

In a series of tweets published on July 26, 2017, President Trump announced a ban on transgender service in the armed forces.  In the wake of this reversal of government policy, employers may question the current state of transgender benefits and whether additional changes are forthcoming. On May 18, 2016, the Department of Health and […]

“Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs” – House Passes Financial Reform Bill

On June 8, the House of Representatives passed the Financial CHOICE Act of 2017 in a bid to reform the financial regulatory system created by the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The bill, which passed the chamber on a vote of 233 to 186, has received support from the Trump Administration but […]