“I was the last one you’d thought you’d see there…”
We tend to think of untimely remittances to retirement plans
as primarily an ERISA issue, and certainly, the cause of many DOL audits.
Lately, however, it seems the IRS also sees late contributions as an invitation
to examine the plan.
https://www.employeebenefitslawblog.com/wp-content/uploads/2022/10/logo_vertical-v2.png00adminhttps://www.employeebenefitslawblog.com/wp-content/uploads/2022/10/logo_vertical-v2.pngadmin2019-11-11 13:22:182019-11-11 13:22:20Friends in Low Places . . . IRS focusing on late contributions too
If you are one of those plan
sponsors who was waiting for the final hardship regulations to be issued before
making any changes to hardship distributions in your plans – your time has
come. The Treasury Department and IRS issued the final regulations on September
19, 2019 for publication today, September 23, 2019.
These regulations finalize
the proposed regulations issued on November 14, 2018, and they are essentially
the same with some clarifications. Plans that made changes in compliance with
the proposed regulations will be deemed to have complied with the final
regulations. Overall the rules – which generally apply to 401(k) plans, 403(b)
plans, and 457(b) plans – ease some of the restrictions on taking hardship
distributions.
https://www.employeebenefitslawblog.com/wp-content/uploads/2022/10/logo_vertical-v2.png00adminhttps://www.employeebenefitslawblog.com/wp-content/uploads/2022/10/logo_vertical-v2.pngadmin2019-09-23 14:45:522019-09-23 15:12:23It’s been a hard day’s night: final hardship distribution rules issued