The Employee Retirement Income Security Act of 1974, as amended (“ERISA”), imposes significant responsibilities upon the plan sponsor of an

On December 29, 2004, the Internal Revenue Service (IRS) issued long awaited final regulations governing cash or deferred arrangements (CODAs)

The Internal Revenue Service (the “IRS”) has issued proposed regulations under Section 403(b) of the Internal Revenue Code (the “Code”),

In October 2004, the Department of Labor issued Field Assistance Bulletin No. 2004–02 (the “Bulletin”) dealing with fiduciary duties with

On October 22, 2004, the President signed the American Jobs Creation Act of 2004 (the “Act”), a major piece of

The Internal Revenue Service has announced the annual cost-of-living adjustments applicable to dollar limitations for pension plans and other items

The Department of Labor (the “DOL”) issued a final regulation on September 28, 2004 that establishes a safe harbor pursuant

New Program On June 15, 2004, the Internal Revenue Service issued final regulations under Section 401(a)(9) of the Internal Revenue

For two decades IRS informal documents, including the Internal Revenue Manual, have allowed plans to make amendments that change the

New Program On May 7, 2004, the Pension Benefit Guaranty Corporation (“PBGC”) announced its new Participant Notice Voluntary Correction Program

In recently published Advisory Opinion 2004–02A, the Department of Labor (the “DOL”) provides guidance concerning modifications made to pre-existing qualified

Introduction Qualified plans generally cannot distribute a benefit prior to normal retirement age without the participant’s consent. However, the law

On April 19, 2004, the Internal Revenue Service (“IRS”) issued Revenue Procedure 2004–25 (“2004–25”), which extends the Remedial Amendment Period

On February 17, 2004, the Internal Revenue Service (the “IRS”) published Revenue Procedure 2004–15, superseding Revenue Procedure 94–41, which outlines

In 2003, the Department of Labor issued Field Assistance Bulletin 2003–3 (the “FAB”), which provides guidance on the allocation of