Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.
Mid-year changes to safe harbor 401(k) plans have long been thought to be available in only very limited circumstances. However, the IRS recently released guidance in Notice 2016-16 that significantly increases the scope of permissible mid-year changes to safe harbor 401(k) plans. Generally, safe harbor 401(k) plan provisions must be adopted (and participants must be […]
The IRS delivered a late Christmas gift December 28, 2015 when, in Notice 2016-4, it extended the Affordable Care Act (“ACA”) reporting deadlines. The new deadlines affect distribution and filing of Forms 1094 and 1095 for calendar year 2015 and are provided below. Section 6055 Health Coverage Reporting Old Filing Deadline New Filing Deadline Form […]
On January 20, 2016, the Supreme Court handed down yet another case addressing health plan subrogation. From the Supreme Court’s earlier decision in Sereboff v. Mid Atlantic Medical Services, Inc. (547 U.S. 356) (2006), we know that a medical plan may use an “equitable lien” to recover on a subrogation claim as long as the […]
Last July, in Announcement 2015-19, the IRS announced that it was terminating its determination letter program for individually designed qualified retirement plans, other than for new or terminating plans. This week, in Notice 2016-03 the IRS provided us with specific transition guidance on the winding down of its program. Specifically, the IRS announced that: Controlled […]
Who doesn’t love a good checklist? I know I do. In the rapidly changing world of employee benefits and executive compensation law, checklists can be particularly helpful to make sure important issues don’t fall through the cracks. To help folks stay apprised of changes in the law, changes they might need to make to their […]
The Treasury Department and the IRS recently issued final regulations (the “2015 Final Regulations”) relating to hybrid retirement plans, including cash balance pension plans. The 2015 Final Regulations provide anti-cutback relief to allow hybrid plans to be amended to change the interest crediting rate to an interest crediting rate that is a market rate of […]
The IRS has announced cost of living adjustments for health flexible spending accounts (“health FSAs”) in Section 125 cafeteria plans, contributions to health savings accounts (“HSAs”), out-of-pocket maximums under high deductible health plans (“HDHPs”) and qualified transportation plan benefits for 2016. For 2016, the health FSA limit on voluntary employee salary reduction contributions will remain […]
The IRS recently announced cost of living adjustments for 2016. In general, the dollar limitations for retirement plans remained the same. The key dollar amounts are noted below, all of which remain unchanged from 2015. Maximum Qualified Retirement Plan Dollar Limits 2015/2016 Limit on Section 401(k) deferrals (Section 402(g)) $18,000 Dollar limitation for catch-up contributions (Section 414(v)(2)(B)(i)) $6,000 Limit on […]
As a reminder, the annual Form 5500 deadline is quickly approaching. Calendar year employee benefit plans that applied for an extension must file Forms 5500 by Thursday, October 15, 2015. The Form 5500 Annual Return/Report of Employee Benefit Plan is a consolidated annual report developed by the Department of Labor (DOL), Internal Revenue Service and […]
The IRS recently released the final forms and instructions for information reporting under the Affordable Care Act (“ACA”). The final forms and instructions will be used for reporting in 2016 concerning 2015 coverage. The final forms and instructions can be accessed below. Form 1094-B Form 1095-B Instructions for Forms 1094-B and 1095-B Form 1094-C Form […]
