The Internal Revenue Service (IRS) is revising the application procedures for pre-approved 403(b) opinions and advisory letters. Revenue Procedure 2015-22 modifies Revenue Procedure 2013-22, 2013-18 I.R.B. 985, as modified by Revenue Procedure 2014-28, 2014-16 I.R.B. 944, and Revenue Procedure 2015-8, 2015-1 I.R.B. 235 to:
Update the addresses to which applications for opinion and advisory letters for § 403(b) pre-approved plans should be submitted; and
To insert a user fee that was omitted from Rev. Proc. 2015-8. Revenue Procedure 2015-22 will be officially published in Internal Revenue Bulletin 2015-11 dated March 16, 2015.
For Advice, Training & Other Resources
If you need assistance with plan design or qualification, monitoring and responding to these and other regulatory policy, enforcement, litigation or other developments, or to review or respond to these or other workforce, benefits and compensation, performance and risk management, compliance, enforcement or management concerns, the author of this update, attorney Cynthia Marcotte Stamer may be able to help.
Board Certified in Labor & Employment Law, Past Chair of the ABA RPTE Employee Benefit & Other Compensation Arrangements Group, Co-Chair and Past Chair of the ABA RPTE Welfare Plan Committee, Vice Chair of the ABA TIPS Employee Benefit Plans Committee, an ABA Joint Committee On Employee Benefits Council representative, Past Chair of the ABA Health Law Section Managed Care & Insurance Section, a Fellow in the American College of Employee Benefit Counsel, ABA, and State Bar of Texas, Ms. Stamer has more than 25 years’ experience advising health plan and employee benefit, insurance, financial services, employer and health industry clients about these and other matters. Ms. Stamer has extensive experience advising and assisting health plans and insurers about ACA, and a wide range of other plan design, administration, data security and privacy and other compliance risk management policies. Ms. Stamer also regularly represents clients and works with Congress and state legislatures, EBSA, IRS, EEOC, OCR and other HHS agencies, state insurance and other regulators, and others. She also publishes and speaks extensively on health and other employee benefit plan and insurance, staffing and human resources, compensation and benefits, technology, public policy, privacy, regulatory and public policy and other operations and risk management concerns. Her publications and insights appear in the Health Care Compliance Association, Atlantic Information Service, Bureau of National Affairs, World At Work, The Wall Street Journal, Business Insurance, the Dallas Morning News, Modern Health Care, Managed Healthcare, Health Leaders, and a many other national and local publications.
You can review other recent human resources, employee benefits and internal controls publications and resources and additional information about the employment, employee benefits and other experience of the Cynthia Marcotte Stamer, PC here. If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information – including your preferred e-mail – by creating or updating your profile www.cynthiastamer.com or by registering to participate in the distribution of these and other updates on our HR & Employee Benefits Update distributions here including:
- Advance Copies Of 2014 Form 5500s Reminder To Avoid Penalties By Confirming Compliance
- Out-Of-Date, Unpatched Software Triggers HIPAA Security Sanction
- 2015 Tax Standard Mileage Rates Announced
- 12/5 Deadline For Insurers, Certain Self-Insured Health Plans To Submit 2014 Transitional Reinsurance Program Contribution Data
- OIG Report Pressures EBSA To Finalize ERISA Fiduciary Investment Advice Rule & Repeal or Restrict Small Scope Audit Rule
- TEGE Counsel To Assume Responsibility For Employee Plans, Exempt Orgs & IRA Technical Guidance in 2015
- Private Exchanges: Employer Health Program Panacea or Problem? Consider Carefully!
- Tell Senate To Pass Fix To ACA’s Full-Time Employee Definition
- Check Out Updated Kaiser Calculator For 2015 Zip Code-Specific Premium and Tax Credit Estimates for Health Marketplace Coverage Coverage
- Ebola Scare & New OCR Privacy Guidance Reminder To Prepare For Pandemic & Other Emergencies
- Stamer Kicks Off Dallas HR 2015 Monthly Lunch Series With 2015 Federal Legislative, Regulatory & Enforcement Update
- New DOL, IRS & HHS FAQ Confirms Employers Can’t Pay, Use HRAs to Reimburse Employees For Individual Policy Premiums
- Review Health Plans With Reference-Based Reimbursement Designs Under New Agency FAQ Guidance
- IRS Raises Health FSA Contribution Limit For 2015
- IRS Guidance Raises Concerns For Many Employers Offering “Skinny” & Other Limited Coverage Health Plans
- Supreme Court Delays Deciding Availabilities of ACA Subsidies For Coverage Purchased On Federal Exchange
- HHS Delays Enforcement Of HIPAA HPID Requirements
- Plan’s Purchase of Company Stock Triggers $6.48 Million Award Against ESOP Sponsor, Shareholder, Board Members & Trustees
- Government Contractors Get More Time To Comment On Burdens Of OFCCP Proposed Compensation Transparency Disclosure Regs
- IRS Announces Employee Plan Cost-Of-Living Adjustments
- Encourage Workers To Review Withholding As Part Of Annual Enrollment
- OFCCP FAQs On Veteran Hiring & Telework Rules
- Encourage Workers To Review Withholding As Part Of Annual Enrollment
- HHS Claims Average $69/Month Cost for Subsidized Coverage Shows ACA Success Challenged
- HIPAA Compliance & Breach Data Shares Helpful Lessons For Health Plans, Providers and Business Associates
- Making Wellness Work On A Shoestring Budget
If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating or updating your profile here. For important information about this communication click here.
NOTE: This article is provided for educational purposes. It is does not establish any attorney-client relationship nor provide or serve as a substitute for legal advice to any individual or organization. Readers must engage properly qualified legal counsel to secure legal advice about the rules discussed in light of specific circumstances.
The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. The Regulations now require that either we (1) include the following disclaimer in most written Federal tax correspondence or (2) undertake significant due diligence that we have not performed (but can perform on request).
ANY STATEMENTS CONTAINED HEREIN ARE NOT INTENDED OR WRITTEN BY THE WRITER TO BE USED, AND NOTHING CONTAINED HEREIN CAN BE USED BY YOU OR ANY OTHER PERSON, FOR THE PURPOSE OF (1) AVOIDING PENALTIES THAT MAY BE IMPOSED UNDER FEDERAL TAX LAW, or (2) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY TAX-RELATED TRANSACTION OR MATTER ADDRESSED HEREIN.
©2014 Cynthia Marcotte Stamer. Limited, non-exclusive right to republished granted to Solutions Law Press, Inc. All other rights reserved.