Understanding Employee Benefits
Understanding Employee Benefits and key developments in the employee benefits field and items of interest to our clients. MORE
On August 31, 2018, President Trump signed an executive order outlining the administration’s priorities for American retirement plans. Emphasizing that as many as 34 percent of workers do not have access to a workplace retirement plan, the order outlines the administration’s plan for increasing workplace retirement plan availability.
The first section of the order outlines…
On April 23, 2018, the DOL released Field Assistance Bulletin (FAB) 2018-01 relating to (1) plan investment in “economically targeted investments (“ETIs”), (2) the exercise of shareholder rights and (3) investment policy statements. We will address the first of these topics in today’s post. Generally, ETIs are investments that promote certain environmental, social and governance…
The IRS announced on April 5th that the agency is seeking input on whether (and how) the individually designed retirement plan determination letter program should be expanded for the 2019 calendar year. Notice 2018-24 requests stakeholder comment regarding additional situations in which sponsors of individually designed plans should have access to favorable determination letter…
29 C.F.R. §2560.503-1
The DOL’s revised ERISA disability claims procedures regulations will be taking effect early next month, and plan sponsors should take a hard look at plan processes over the next few weeks to ensure compliance. The new requirements apply to disability benefit claims filed after April 1, 2018, after a 90-day delay postponed…
I have written a number of posts (here, here, and here) on employers and business owners who have been held responsible for the multiemployer plan withdrawal liability of a different employer. In some cases, the liability comes from common ownership. In other cases, the liability comes because a new business is…
I noticed an interesting case from the Tenth Circuit which found that a two to three percent working interest in an oil and gas venture could generate self-employment income for the owner of that interest. The individual in question entered into both a purchase agreement and an operating agreement with the operator of the oil…
IRS Annual Limits on Qualified Plans for 2017
On October 27, 2016, the Internal Revenue Service released the 2017 cost of living adjustments affecting dollar limits on benefits and contributions under qualified retirement plans and health savings accounts. Changes from 2016 were minimal. Notice 2016-62 is available here.
The following chart summarizes the 2017…
On September 16, 2016, the IRS and the Department of the Treasury requested public comment on ways the IRS and Treasury “can improve compliance…by making it easier for plan sponsors to satisfy requirements for qualified plan documents” in the wake of the determination letter program changes (Announcement 2016-32). In June, the Internal Revenue…
Many employers self-administer welfare benefit plans such as life insurance or disability insurance plans. This self administration requires the employer to determine eligibility for coverage, remit proper premiums and notify the insurance carrier about changes in coverage. The insurance carrier often does not even know the names of the covered individuals and the coverage amounts.…
The US Department of Labor (DOL) has proposed changes to the Form 5500 and schedules that will affect ERISA Title I group health plans of all sizes, but small group health plans should be especially aware of the changes. Certain small group health plans (fewer than 100 participants) are currently exempt from filing the Form…
