Employee Benefits & Executive Compensation Blog

The View from Proskauer on Developments in the World of Employee Benefits, Executive Compensation & ERISA Litigation

Tag Archives: Internal Revenue Service

IRS Opens Determination Letter Program to Individually Designed 403(b) Plans

On October 21st, the IRS announced changes to its qualified plan determination letter program. Most notably, the program has been expanded to include section 403(b) tax-sheltered annuity plans (“403(b) plans”). Although 403(b) plans are similar to tax-qualified defined contribution plans (“401(a) plans”), they are subject to unique rules, and, until now, the IRS has not … Continue Reading

IRS Announces 2023 Increases to Qualified Retirement Plan Limits

On October 21st, the IRS released a number of additional inflation adjustments for 2023, including to certain limits for qualified retirement plans.  Perhaps most notably, the annual limit for pre-tax and Roth contributions by employees to 401(k) plans has jumped from $20,500 to $22,500, and the annual limit for “catch-up” contributions to such plans by … Continue Reading

IRS Announces 2023 Increases to Health FSA and Transportation Fringe Benefit Limits

On October 18th, the IRS announced a slew of inflation adjustments for 2023, including to the annual contribution and carryover limits for healthcare flexible spending accounts and the monthly limit for qualified transportation fringe benefits.  The IRS did not increase the annual contribution limit for dependent care flexible spending accounts because that limit is not … Continue Reading

Changes to the IRS Determination Letter Program

The IRS has informally stated that it is intending to make some significant changes to the Determination Letter program, and is even considering eliminating the program for individually designed retirement plans (other than perhaps initial and final determination letters).  The agency apparently is looking to streamline its operations and focus its resources on other areas. … Continue Reading

What Does PPACA Stand For? Punitive Penalties Are Clearly Authorized

A recently posted IRS Q&A raises the specter of serious penalties for non-compliance with the Affordable Care Act. The context of the question relates to the consequences to employers that do not establish a health insurance plan for their own employees, but instead reimburse them for premiums they pay for other health insurance. The IRS … Continue Reading

District Court Upholds Validity of IRS Rule Authorizing Premium Tax Credits to Individuals Who Enroll in Health-Care Coverage through Federally-Facilitated Exchanges

A district court in the District of Columbia recently held that the Internal Revenue Service’s (“IRS”) rule authorizing premium tax credits to individuals who enroll in health-care coverage through federal exchanges was unambiguously consistent with the “text, structure, and purpose” of the Affordable Care Act (“ACA”). Halbig v. Sebelius, No. 13-cv-0623, 2014 U.S. Dist. LEXIS … Continue Reading
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