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January 10, 2008
New Proposed Regulations
New Medicare Reporting Obligations
As part of the Medicare, Medicaid and SCHIP Extension Act of 2007 (S. 2499) signed into law by President Bush on December 29, 2007, a new Medicare secondary payor reporting rule is imposed, primarily on insurers and third party administrators (TPAs).
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.
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.
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.
November 5, 2007
2008 Cost of Living Adjustments
2008 Retirement Plan COLAs
Medicare Part D Notice: Don't Forget!
PPA Notices Re-visited
Qualified Default Investment Alternatives
Delay of 409A Implementation
The IRS recently issued Notice 2007-86, which extends thedeadline for compliance with 409A rules until December 31, 2008.
October 9, 2007
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.