The Internal Revenue Service has issued two pieces of new guidance addressing retirement-related corrections: a much-anticipated update to the IRS correction program for addressing tax-qualified retirement plan errors and a new correction program that provides important relief opportunities for owners
ML BeneBits
ML BeneBits, published by Morgan Lewis, focuses on legal developments and practical guidance related to employee benefits and executive compensation. The blog covers topics such as ERISA compliance, wellness program litigation, restrictive covenants in corporate transactions, annual benefits enrollment strategies, and regulatory updates from the Department of Labor. It also addresses emerging trends in retirement investing, including the impact of executive orders on alternative investment options within retirement plans. The content is aimed at plan sponsors, human resources professionals, and executives navigating the complexities of benefits administration and regulatory compliance.
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PBGC Announces Multiemployer Pension Premiums for 2027
By Morgan Lewis
The Pension Benefit Guaranty Corporation announced on October 14, 2026 that for 2027 premiums for multiemployer pension plans will be a flat $42 per participant. This represents a 5% increase from 2026 rates (a $2 increase) and a 40% increase…
California Amends Stay-or-Pay Law
By Morgan Lewis
California’s stay-or-pay law generally prohibits contracts that require workers to repay “debts” upon leaving their employer unless the contract satisfies certain statutory requirements. As originally enacted, the law applied to contracts entered into on or after January 1, 2026. Many…
PBGC Waives Requirement to Report Attrition Events Under Its Reportable Events Regulation
By Morgan Lewis
The Pension Benefit Guaranty Corporation (PBGC) issued Technical Update No. 26-1 on September 18, 2026, which waives on a prospective basis the requirement to report an attrition event under the agency’s reportable events regulation, which can be found at 29…
What Goes Around: IRS Audits of Fixed Indemnity Health/Wellness Benefit Plans that Offer Purported Tax Savings
By Morgan Lewis
The Internal Revenue Service (IRS) has begun to audit fixed indemnity health/wellness benefit plans that have been marketed by promising significant payroll tax savings to employers and employees. The IRS has long disagreed with the claimed tax treatment, issuing a…
Don’t Call It a Comeback: PBGC Relaunches Opinion Letter Program
By Morgan Lewis
The Pension Benefit Guaranty Corporation (PBGC) has relaunched its Opinion Letter Program to provide enhanced compliance guidance under Title IV of ERISA. Employers, plan sponsors, unions, and practitioners can request opinion letters to clarify PBGC’s application of ERISA regulations to…
PBGC Provides Merger Guidance for SFA Plans 5 Years After Enactment of American Rescue Plan Act
By Morgan Lewis
Five years after the US Congress enacted the American Rescue Plan Act’s Special Financial Assistance (SFA) program, the Pension Benefit Guaranty Corporation (PBGC) has issued new guidance addressing what happens when a plan that received SFA wants to merge with…
Designing Executive Loan Programs in the Context of Incentive Equity: Key Considerations and Practices
By Morgan Lewis
Executive loan programs have become a popular strategic response to complex executive compensation demands in a competitive talent market.
Roth Catch-Up Rules Finalized: What Multiemployer Plans Need to Know
By Morgan Lewis
The US Department of the Treasury and the Internal Revenue Service have finalized regulations under the SECURE 2.0 Act that change how certain retirement plan participants may make catch-up contributions. Beginning in 2026, participants whose income meets certain thresholds and…
IRS Postpones Effective Date of Certain RMD Regulations
By Morgan Lewis
In Announcement 2026-7 , the Internal Revenue Service (IRS) further delayed the application of certain required minimum distribution (RMD) proposed regulations until January 1, 2027, at the earliest. The delayed proposed regulations addressed certain changes to the RMD rules made…