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COBRA Compliance - Still Relevant in 2018!
Although COBRA has been in effect since 1985, employers still struggle with compliance, whether with everyday COBRA administration or ...
Jul 1, 20191 min read


Multiple Employer Plans and Saving the Barrel from the One Bad Apple
A multiple employer plan (“MEP”) is a tax qualified retirement plan that is maintained by two or more employers that are not part...
Jun 30, 20195 min read
California Enacts Individual Mandate and Premium Subsidies
With the Fifth Circuit Court of Appeals on the verge of determining the constitutionality and continued viability of the...
Jun 30, 20195 min read
The New CalSavers Law Takes Effect on July 1, 2019: What Employers Need to Do Now
The California Secure Choice Retirement Savings Trust Act (“CalSavers”) takes effect on July 1, 2019. Large employers that have at least...
May 31, 20195 min read
IRS Expands Self Correction Program in New EPCRS Procedure
The IRS has yet again updated the Employee Plans Compliance Resolution System (EPCRS), this time expanding the use of the Self ...
Apr 30, 20193 min read
What is a VCP?
A VCP is a submission to the IRS through its Voluntary Correction Program offered under the Employee Plans Compliance Resolution System...
Apr 30, 20192 min read
IRS Opens the Door to Determination Letter Applications for Merged and Cash Balance Individually...
IRS Opens the Door to Determination Letter Applications for Merged and Cash Balance Individually Designed Plans Revenue Procedure ...
Apr 30, 20194 min read
Self Directed IRAs: ERISA Issues Related to Non-Traditional Investments
The Initial Formation of a Self-Directed IRA Structure The landmark case of Swanson v. Commissioner, 106 T.C. 76 (1996) confirmed that an...
Mar 31, 20195 min read
Plan Amendment Deadlines and More
There is an old saying that goes: “Hindsight is 20/20,” but in the case of required plan amendments, that is not the case. Specific...
Mar 31, 20194 min read
Plan Termination Determination Letters: Form 5310 Pros and Cons
As of July 1, 2019, employers applying to the IRS for a favorable determination for a terminating plan will have to pay an ...
Feb 28, 20193 min read


A One-Time Offer from the IRS for 403(b) Plans Nears its Expiration Date
Albert Einstein theorized that because time is relative, a space traveler who leaves earth and travels near the speed of light ...
Feb 28, 20195 min read
Self-Directed IRAs: Your Personal Interests ns. Your IRA's Interests
IRA owners who self-direct their IRA’s investments serve in a fiduciary capacity to their IRA and are subject to a variety of...
Jan 31, 20195 min read
Proposed Rules to Expand HRAs Part 3: The Impact of Individual Coverage HRAs on PTC Eligibility (IRC
Proposed Rules to Expand HRAs Part 3: The Impact of Individual Coverage HRAs on PTC Eligibility (IRC Section 36B) and the Employer Shared...
Dec 31, 20186 min read
Unpacking the Settlor - Fiduciary "Two Hat" Principle
The difference between an employer’s “settlor” and “fiduciary” role with respect to its employee benefit plans, the so-called...
Dec 31, 20185 min read
What is a “Prohibited Transaction” under ERISA?
Section 406(a) of the Employee Retirement Income Security Act of 1974 (“ERISA”) broadly prohibits plan fiduciaries from...
Mar 30, 20182 min read
What is a QSLOB?
In addition to being a favorite acronym under the Internal Revenue Code, and there are plenty to choose from, a QSLOB is...
Nov 29, 20172 min read
What is a MEWA?
“MEWA” stands for “multiple employer welfare arrangement.” A MEWA is formed when a health and welfare plan provides benefits to employees...
Oct 31, 20172 min read
10 Questions to Ask Before Signing That New Service Agreement
“Attached is Our Standard Service Agreement...” Sound familiar? If not, it may shortly – it is widely expected that retirement plan...
Oct 31, 20166 min read


Top Hat Plan Basics
Top Hat plans are deferred compensation plans designed to benefit top management. They are exempt from most of ERISA’s...
Oct 21, 20162 min read
R=(CC or ASG)²: The Risk of Relativity
Although the title of this article may be a bit tongue in cheek, the business risks to a law firm (or its clients) of unknowingly being...
Nov 1, 20156 min read
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