SECURE 2.0: IRS Issues New Guidance on RMDs

NICOLAS DEGUINES, September 21, 2023 On July 14, 2023, the Internal Revenue Service (the “IRS”) issued Notice 2023-54 (the “Notice”), providing much-welcomed guidance and transition relief relating to certain required minimum distributions (RMDs). Specifically, the Notice provides the following: Relief for the change in the required beginning date (RBD) for RMDs under SECURE 2.0; Guidance […]

Trucker Huss Lawyers Recognized as 2024 Best Lawyers®and Best Lawyers: Ones to Watch®

BULLETIN, August 30, 2023 Trucker Huss is pleased to announce that Best Lawyers® has recognized 13 of our lawyers:  ten have been included in the 2024 edition of The Best Lawyers in America® and three have been named to the 2024 Best Lawyers: Ones to Watch® list. Since it was first published in 1983, Best […]

More Time to “Catch-Up”

ZACHARY ISENHOUR and ROBERT GOWER, August 29, 2023 On August 25, 2023, the Internal Revenue Service (IRS) released Notice 2023-62 (the “Notice”), providing eagerly awaited relief on the implementation timeline for the catch-up contribution provisions under Section 603 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”). The catch-up contribution provisions under Section 414(v) of […]

Ninth Circuit Decision in AT&T Case Could Open Up Potential New Attacks on Retirement Plan Fiduciaries: What Fiduciaries Need to Know

DYLAN D. RUDOLPH and JOSEPH C. FAUCHER,  August 10, 2023 On August 4, 2023, the Ninth Circuit Court of Appeals revived a lawsuit against AT&T Services Inc. and its retirement plan fiduciaries (together, “AT&T”), reversing a district court’s order granting summary judgment in AT&T’s favor. This decision, which is published and binding on cases located […]

Coming Soon: Determination Letter Program for Individually Designed Section 403(b) Plans

JAHIZ NOEL AGARD and KATURI KAYE, April 27, 2023 Starting in June 2023, the Internal Revenue Service (the “IRS”) will start accepting determination letter applications for individually designed Internal Revenue Code Section 403(b) plans (“section 403(b) plans”) (also known as tax-sheltered annuity plans). As announced in Revenue Procedure 2022-40 (issued in November 2022), plan sponsors […]

Group Health Plans Must Submit Gag Clause Attestations by December 31, 2023

ALAINA HARWOOD and ELIZABETH LOH, April 27, 2023 On February 23, 2023, the U.S. Departments of Labor, Health and Human Services, and Treasury (the “Departments”) issued joint guidance (“Tri-Agency FAQs”) for group health plans and insurers regarding annual attestations on gag clause prohibition compliance as required under the Consolidated Appropriations Act, 2021 (CAA). Attestations will […]