On May 28, 2019, the IRS released Revenue Procedure 2019-25 setting dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2020. HSAs are subject to annual aggregate contribution limits (i.e., employee and dependent contributions plus employer contributions). HSA participants age 55 or older can contribute additional catch-up contributions. Additionally, in order
Damian A. Myers
IRS Announces Limited Expansion of its Determination Letter Program for Individually Designed Retirement Plans – But Questions Remain
By Damian A. Myers & Jennifer Rigterink on
On May 1, 2019, the IRS released Revenue Procedure 2019-20 which provides for a limited-scope expansion of its determination letter program for individually designed plans. Beginning on September 1, 2019, the IRS will accept determination letter applications submitted for the following types of plans:
- Statutory hybrid plans (e.g., cash balance or pension equity plans). Applications
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New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching
By Seth Safra, Steven Weinstein & Damian A. Myers on
As discussed here, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off guard. The tax is 21% of certain compensation paid to the top five highest paid employees of the tax-exempt…
Nationwide Injunction Halts Exemptions and Accommodations to the ACA Contraceptive Coverage Mandate
On January 14, 2019, a district court in the Eastern District of Pennsylvania granted a nationwide preliminary injunction halting the application of final regulations governing religious and moral-based exemptions from the Affordable Care Act (“ACA”) mandate to cover contraceptives without cost sharing. The final regulations would have dramatically expanded the scope of existing exemptions and…