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 […]
MC
Due to the increased litigation of air ambulance claims, employers may want to review their plan language to see whether their group health plan covers air ambulance services, and if so, to better understand the terms of the coverage. Below are three issues employers may want to consider: Expensive and Often Out-of-Network. Air ambulance claims […]
AB
Tax reform made few changes that directly impact qualified retirement plans; however, it made some changes that may indirectly impact qualified retirement plans. We previously blogged on the indirect changes that tax reform had on hardship distributions. Tax reform also made changes to the taxation of certain fringe benefits that may impact the definition of […]
AM
Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A provides that a payment will not be considered nonqualified deferred compensation if the employer makes the payment on or prior to the 15th day […]
GG
Section 4980I, which was added to the Internal Revenue Code by the Affordable Care Act, was originally supposed to take effect in 2018. This tax is commonly called the “Cadillac tax” because it imposes a 40% excise tax on high cost employer sponsored health coverage. The Consolidated Appropriations Act signed into law on December 18, […]
NC
When tax reform proposals were floating around in the fall of 2017, several early proposals to the Tax Cuts and Jobs Act (the “Act”) included changes to the hardship distribution rules for qualified retirement plans. However, the final version of the Act did not make any direct changes to hardship distributions. Nevertheless, the Act, perhaps […]
KP
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 […]
MC
As reported in Part 3 of our 2016 End of Year Plan Sponsor “To Do” List, Section 6039 of the Code requires employers to provide a written information statement to each employee or former employee and file information returns with the IRS regarding: (1) the transfer of stock pursuant to the exercise of an Incentive […]
GG
As noted in our previous blog post, The New Disability Claims Regulations: They Don’t Only Apply to Disability Plans, the Department of Labor (“DOL”) issued regulations that revise the ERISA claims procedure regulations for all employee benefit plans that provide disability benefits (the “New Regulations”). These rules can impact not only short-term and long-term disability […]
AB
In our 2017 End of Year Plan Sponsor “To Do” List (Part 4) Qualified Plans, we suggested that sponsors of all qualified retirement plans should be on the lookout for the Internal Revenue Service’s (“IRS”) 2017 Required Amendments List (“RA List”). The IRS recently published Notice 2017-72, which contains the 2017 RA List, https://www.irs.gov/pub/irs-drop/n-17-72.pdf. […]
AM
SV