In Announcement 2016-39 issued on October 21, 2016, the IRS follows its long-standing practice and eases application of the qualified plan loan and/or hardship rules for those who were impacted by Hurricane Mathew. For example, the relief allows impacted individuals to obtain a hardship distribution without the need to prove a hardship based on the types enumerated in the regulations. Further, no post-hardship distribution contribution restrictions are required.
The relief applies to...Continue Reading
In July of 2015, the IRS announced that it would end its regular determination letter program for individually designed plans effective January 1, 2017. At the time of this announcement, many plan sponsors and other interested stakeholders expressed concern about how this seismic change would impact the retirement plan landscape. In several pieces of guidance issued in 2016, the IRS has answered many of the questions as to how the end of the determination letter program will impact...Continue Reading
Unlike the forms for the 2015 calendar year, the 2016 Forms 1095-C must be provided to employees by January 31 and must be submitted to the IRS electronically by March 31 (for those with under 250 forms submitting on paper, the deadline is February 28). Newly revised forms and instructions for this purpose have just been released. Although the forms have not changed much, the instructions have changed significantly. The penalties for failing to file a correct form with the IRS or an...Continue Reading
On September 30, 2016, the United States Department of Labor, implementing Executive Order 13706, published its final rule establishing paid sick leave requirements for certain federal contractors. The final rule will apply to all employers with covered federal contracts that result from solicitations issued on or after January 1, 2017, that are awarded outside the solicitation process on or after January 1, 2017, or that are renewed, extended, or amended on or after January 1, 2017 as a...Continue Reading
On September 25, 2016, Governor Jerry Brown of California signed into law a new state statute that, in most instances, prohibits agreements requiring California-based employees to litigate or arbitrate their California-based employment-related claims in other states. The new statute, which will apply to contracts entered into, modified, or extended on or after January 1, 2017, applies generally to agreements with employees who primarily reside or work in California. Please see our Legal...Continue Reading