Topic: Retirement Plans

In late December 2023, approximately one year after Congress enacted the Setting Every Community Up for Retirement Enhancement Act of 2022 (“SECURE 2.0”), the Internal Revenue Service (the “IRS”) released Notice 2024-2 (the “Notice”) providing much needed guidance, in the form of questions and answers, on 12 of the 90 new provisions added by SECURE 2.0.

The Internal Revenue Service announced the 2024 cost-of-living adjustments to the dollar ‎limitations for qualified retirement plans and other benefits, and the Social Security ‎Administration announced its own cost-of-living adjustments for 2024. Most of the dollar ‎limits, including the elective deferral contribution limit for 401(k), 403(b) and 457(b) plans, the ‎annual compensation limit under 401(a)(17) and the maximum annual contribution limit under ‎Code Section 415(c) will increase from 2023 limits. The dollar limit for catch-up contributions ‎‎(if age 50 or older) remains the same as the 2023 limit.‎

Long-awaited guidance was received from the IRS on Friday related to the SECURE 2.0 ‎requirement that catch-up contributions for high-income participants in 401(k), 403(b), and ‎governmental 457(b) plans be made as Roth contributions. Notice 2023-62 provides for a 2-year ‎administrative transition period that will be welcome relief to retirement plan sponsors and ‎record keepers alike.

The Internal Revenue Service announced the 2023 cost-of-living adjustments to the dollar ‎limitations for qualified retirement plans and other benefits, and the Social Security ‎Administration announced its own cost-of-living adjustments for 2023. All of the dollar limits, ‎including the elective deferral contribution limit for 401(k), 403(b) and 457(b) plans, the ‎annual compensation limit under 401(a)(17), the maximum annual contribution limit under ‎Code Section 415(c) and the dollar limit for catch-up contributions (if age 50 or older) will ‎increase from 2022 limits.‎

On August 3, 2022, the Internal Revenue Service issued IRS Notice 2022-33, which extends the ‎deadline for amending certain plans with the applicable requirements of the Setting Every ‎Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the Bipartisan ‎American Miners Act of 2019 (Miners Act), and one provision of the Coronavirus Aid, Relief, ‎and Economic Security Act (CARES Act).‎

In its June 3, 2022 Employee Plans Newsletter, the IRS announced a pilot pre-‎examination retirement plan compliance program beginning in June 2022. Under the pilot ‎program, the IRS will notify a qualified plan sponsor by letter that its retirement plan has been ‎selected for an upcoming examination.‎