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January 10, 2008
Retiree Health and Age Discrimination…the Final Scene?
On December 26, 2007, the Equal Employment Opportunity Commission (EEOC) issued final regulations supporting the long-standing practice of coordinating retiree health benefits with Medicare. This matter was challenged several years ago in the Erie County case (see Retiree Health Coordination on the Move Again?, Retiree Health Rules Rolling Again, and Coordination of Retiree Health Benefits with Medicare). Since then, the pendulum has swung back and forth. While it may still be swinging, its arc is short and slow.
December 6, 2007
Enforcement of Revised Form I-9
The US Citizenship and Immigration Services (USCIS) recently announced that all US employers must begin using a revised Form I-9 for all newly hired employees, and for all employees whose status requires re-verification. The I-9 Form has been revised to bring it into compliance with existing regulations. According to USCIS, this new form is the only form that should be used, beginning on or after 11/7/07. If this Form is not used after 12/26/07, then penalties may be assessed.
IRS Issues Model 403(b) Plan
In July, 2007, the final 403(b) regulations were issued. These regulations require that all 403(b) plans be governed by a written plan document. Often, plans exempt from ERISA have not maintained a written plan document governing their programs.
PPA Notices…Re-Visited Again!
The IRS and Treasury have been busy issuing guidance that will assist plan sponsors in their efforts to make certain retirement plans remain qualified.
November 5, 2007
Delay of 409A Implementation
The IRS recently issued Notice 2007-86, which extends thedeadline for compliance with 409A rules until December 31, 2008.
2008 Cost of Living Adjustments
2008 Retirement Plan COLAs
PPA Notices Re-visited
Qualified Default Investment Alternatives
Medicare Part D Notice: Don't Forget!
October 9, 2007
Time Now for New Massachusetts Filings by Employers
The Massachusetts health care reform law passed last year requires employers who employ 11 or more full-time equivalent employees in the Commonwealth to accomplish certain filings between October 1st and November 15th of each year. The first filing period is upon us.
409A Documentation Limited Relief
409A is a tax code regulating nonqualified deferred compensation. It was enacted in October 2004, and the time for compliance is upon us. Generally, nonqualified deferred compensation plans must comply with the 409A rules beginning January 1, 2008, or risk substantial penalties, both to participant and employer.