T. Katuri Kaye

Internal Revenue Service Provides Transition Relief to Code Section 403(b) Plans for Violations of the Once-In-Always-In Rule

T. KATURI KAYE and BRIANA B. DESCH, April, 2019      The Internal Revenue Service (IRS) recently issued guidance providing transition relief to employers who have not correctly applied the “once-in-always-in” rule (the “OIAI rule”) and, as a result, have wrongfully excluded part-time employees from participating in their Internal Revenue Code (Code) Section 403(b) plans. […]

California to Move Forward with Auto-IRA Despite Loss of ERISA Safe Harbor

T. KATURI KAYE, June 2017    On May 18, 2017, California State Treasurer John Chiang and Senate President Pro Tempore Kevin de León (D-Los Angeles) issued a press statement announcing that California remains on track to implement the California Secure Choice Retirement Savings Program (“Secure Choice” or the “Program”), a state-sponsored program requiring employers that […]

Internal Revenue Service Provides Guidance on the Scope of the New Determination Letter Program for Individually Designed Plans

T. KATURI KAYE, July 2016 — The IRS issued Revenue Procedure 2016-37 on June 29, 2016, which provides much anticipated guidance on the elimination of the determination letter program for individually designed retirement plans effective January 1, 2017. The following is a summary of Revenue Procedure 2016-37 in order to assist plan sponsors with making […]

IRS Provides Guidance on Mid-Year Changes to Safe Harbor Plans

T. KATURI KAYE, February 2016 – On January 29, 2016, the Internal Revenue Service (“IRS”) issued Notice 2016-6 (the “Notice”), providing important guidance on mid-year changes to safe harbor plans under Sections 401(k), 401(m) and 403(b) (collectively referred to as “safe harbor plans”) of the Internal Revenue Code (the “Code”). The Notice is welcome guidance […]

IRS Issues Final Regulations on the Determination of Minimum Required Contributions for Single Employer Defined Benefit Plans

T. KATURI KAYE, September 2015 — On September 9, 2015, the Internal Revenue Service (“IRS”) issued final regulations on determining minimum required pension contributions under Internal Revenue Code (“Code”) section 430 for single employer defined benefit pension plans for plan years beginning on or after January 1, 2016. Code section 430 was added by the […]