On April 23, 2024 the Federal Trade Commission (FTC) issued its final rule that prohibits most non-compete clauses. The rule is effective 120 days after its publishing in the Federal Register (scheduled for May 7). However, lawsuits challenging the rule
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Notice 2024-02 Guidance on Distributions to the Terminally Ill
This article is the fifth in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 as Notice 2024-02 (Notice).…
When Automatic Isn’t Automatic: Notice 2024-02 Guidance on Self-Correcting Auto-Enrollment And Auto-Escalation Failures
This article is the fourth in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 as Notice 2024-02 (Notice).…
New Plan Automatic Enrollment Guidance Under IRS Notice 2024-02
This article is the third in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 as Notice 2024-02 (Notice).…
Guidance on Roth Matching or Nonelective Contributions in IRS Notice 2024-02
This article is the second in the series addressing the 81 pages of guidance on the legislation known as SECURE 2.0 (the Act) enacted on December 29, 2022, issued by the IRS on December 20, 2023 in Notice 2024-02 (Notice).…
Notice 2024-02 Extends Deadline For SECURE 2.0 Amendments And Provides Other Guidance
On December 20, 2023 the IRS gave plan sponsors an early Christmas gift of 81 pages of guidance on a myriad of employee benefit plan law changes in the legislation known as SECURE 2.0 (Act) when it issued IRS Notice…
IRS Announces 2024 Plan Limitations
On November 1, 2023, the IRS announced the inflation adjusted benefit plan limitations effective in 2024 in Notice 2023-75. The good news is the amount that can be electively deferred into a 401(k) or 403(b) plan increases from the current…
Ten Common Mistakes in 457 Plans of Tax Exempt Organizations–Part 2
Last month, in Part 1 of this blog on 10 common mistakes in 457 plans sponsored by tax exempt organizations (EOs), I gave the first five common mistakes I’ve seen in my practice working with these sponsors. See “Ten…
Ten Common Mistakes In 457 Plans of Tax Exempt Organizations–Part 1
In May, I blogged how 457 plans are bipolar in two ways. First, Internal Revenue Code (Code) section 457 describes the tax consequences of unfunded deferred compensation plans for both tax exempt organizations and state and local governments and the…
The Western Benefits Conference is Back!
I am pleased to announce I will be attending the Western Benefits Conference at the Westin Kierland in Scottsdale, AZ in October. After a few years without having a conference due to the pandemic, the Western Pension & Benefits Council…