T. Katuri Kaye

Internal Revenue Service Updates the Employee Plans Compliance Resolution System under Revenue Procedure 2021–30

T. KATURI KAYE and NICOLAS DEGUINES, August, 2021  On July 16, 2021, the Internal Revenue Service (IRS) released Revenue Procedure 2021-30, an updated version of the Employee Plans Comp­liance Resolution System (EPCRS), which we will refer to in this article as the “EPCRS Update.” This article summarizes the significant changes and revisions made by the […]

Retirement Plan Relief in Consolidated Appropriations Act, 2021

T. KATURI KAYE and CATHERINE L. REAGAN, January 14, 2021   Signed by the President in December, the Consolidated Appropriations Act, 2021 (CAA) combines COVID-19 stimulus relief with a number of year-end appropriations bills, and it includes numerous provisions that will impact retirement plans. The retirement plan relief provisions in the CAA are divided between (1) […]

Impact of the Historic Coronavirus Aid, Relief and Economic Security Act on Retirement Plans — and Action Items for Plan Sponsors

T. KATURI KAYE and BRYAN J. CARD, March, 2020    On March 27, 2020, the United Sates Congress passed the historic Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”), the largest rescue bill to date, which provides economic relief to individuals, businesses, local and state governments, and health care systems financially impacted by […]

Internal Revenue Service Provides Transition Relief to Code Section 403(b) Plans for Violations of the Once-In-Always-In Rule

T. KATURI KAYE and BRIANA B. DESCH, April, 2019      The Internal Revenue Service (IRS) recently issued guidance providing transition relief to employers who have not correctly applied the “once-in-always-in” rule (the “OIAI rule”) and, as a result, have wrongfully excluded part-time employees from participating in their Internal Revenue Code (Code) Section 403(b) plans. […]

California to Move Forward with Auto-IRA Despite Loss of ERISA Safe Harbor

T. KATURI KAYE, June 2017    On May 18, 2017, California State Treasurer John Chiang and Senate President Pro Tempore Kevin de León (D-Los Angeles) issued a press statement announcing that California remains on track to implement the California Secure Choice Retirement Savings Program (“Secure Choice” or the “Program”), a state-sponsored program requiring employers that […]

Internal Revenue Service Provides Guidance on the Scope of the New Determination Letter Program for Individually Designed Plans

T. KATURI KAYE, July 2016 — The IRS issued Revenue Procedure 2016-37 on June 29, 2016, which provides much anticipated guidance on the elimination of the determination letter program for individually designed retirement plans effective January 1, 2017. The following is a summary of Revenue Procedure 2016-37 in order to assist plan sponsors with making […]

IRS Provides Guidance on Mid-Year Changes to Safe Harbor Plans

T. KATURI KAYE, February 2016 – On January 29, 2016, the Internal Revenue Service (“IRS”) issued Notice 2016-6 (the “Notice”), providing important guidance on mid-year changes to safe harbor plans under Sections 401(k), 401(m) and 403(b) (collectively referred to as “safe harbor plans”) of the Internal Revenue Code (the “Code”). The Notice is welcome guidance […]

IRS Issues Final Regulations on the Determination of Minimum Required Contributions for Single Employer Defined Benefit Plans

T. KATURI KAYE, September 2015 — On September 9, 2015, the Internal Revenue Service (“IRS”) issued final regulations on determining minimum required pension contributions under Internal Revenue Code (“Code”) section 430 for single employer defined benefit pension plans for plan years beginning on or after January 1, 2016. Code section 430 was added by the […]