On April 29, 2020, the U.S. Departments of Labor (Employee Benefits Security Administration, “EBSA”) and Treasury (IRS) published a final regulation, and EBSA issued a package of guidance and relief, for employee benefit plans affected by the COVID-19 outbreak. EBSA’s package includes (i) EBSA Disaster Relief Notice 2020-1, (ii) DOL COVID-19 FAQs for Participants and … Continue Reading
Search Results for: deadline extension
PBGC Announces COVID-19 Extensions for Premium Payments and Other Filing Deadlines
On April 10, 2020, the Pension Benefit Guaranty Corporation (the “PBGC”) announced that deadlines for upcoming premium payments and certain other required filings due from April 1, 2020 through July 14, 2020 will be extended to July 15, 2020 as further described below. The PBGC’s announcement came a day after the Internal Revenue Service (the … Continue Reading
IRS Extends ACA Reporting Deadline and Issues Transition Relief
The IRS has not yet finalized the ACA reporting forms (i.e., the 1094-B/C and 1095-B/C) for the 2019 tax year, so it is no surprise that the IRS issued guidance this week extending the deadline to furnish the forms to employees and covered individuals (see Notice 2019-63). In addition to extending the deadline to furnish … Continue Reading
The Deadline for 403(b) Sponsors to Review Plan Documents for Compliance is Approaching
Section 403(b) plans must be maintained pursuant to a written plan document that meets detailed requirements set forth in IRS regulations. If a plan contains a defect as to form (e.g., a provision does not comply with the regulations or a required provision is missing), the plan can be at risk for losing its qualification … Continue Reading
IRS Once Again Extends Distribution (Not Filing) Deadline for ACA Reporting and Continues Good Faith Standard
Following the old “better late than never” axiom, the IRS recently announced (see Notice 2018-06) that once again it would be extending the distribution (but not filing) deadline for the Affordable Care Act (ACA) reporting requirements set forth in Sections 6055 and 6056 of the Internal Revenue Code (the “Code”). Under Code Section 6055, health … Continue Reading
IRS Extends Distribution (Not Filing) Deadline for ACA Reporting and Continues Good Faith Standard
Today, the IRS announced (see Notice 2016-70) an extension to the distribution (but not filing) deadline for the Affordable Care Act (ACA) reporting requirements set forth in Sections 6055 and 6056 of the Internal Revenue Code (the “Code”). Under Code Section 6055, health coverage providers are required to file with the IRS, and distribute to … Continue Reading
IRS Extends Deadlines for Affordable Care Act Reporting
Today, the IRS released Notice 2016-4, which extended the distribution and filing deadlines for the Affordable Care Act (ACA) reporting requirements set forth in Sections 6055 and 6056 of the Internal Revenue Code (the “Code”). Under Code Section 6055, health coverage providers are required to file with the IRS, and distribute to covered individuals, forms … Continue Reading
For Whom the Statute Tolls
As discussed in an earlier blog post on the DOL/Treasury relief extending benefit plan deadlines due to the pandemic, plans have to disregard an “outbreak period” when determining deadlines for COBRA elections and premiums payments, special enrollment in health plans, and the filing of claims and appeals. The DOL/Treasury guidance defined the “outbreak period” as … Continue Reading
Additional Relief for FSA Benefits
As part of the COVID-19 relief package passed by Congress earlier this week, the federal government expands on earlier relief issued by the Internal Revenue Service (IRS) for health and dependent care flexible spending account benefits (FSAs). Under these temporary rules, plan sponsors may give their employees additional time to use their FSA account balances … Continue Reading
Side by Side Comparison: Electronic Disclosure Rules for Pension & Welfare Plans
The DOL recently provided retirement plans with a new method to comply electronically with certain participant disclosure and notice requirements. See our blog post outlining the new DOL rule. This new method adds to the previously issued DOL safe harbor and the IRS rules. Below is a side-by-side general comparison to help plan administrators keep … Continue Reading