Last week at the American Bar Association’s (ABA’s) virtual, multi-day 2023 fall tax meeting, US Treasury Department attorney-advisors confirmed that the IRS is prioritizing “grab bag” SECURE 2.0 guidance as year-end nears.
Expected provisions to be addressed include cash incentives for participating in employer-sponsored plans; and employer tax credits for new plans.
A Treasury representative also stated that the guidance likely won’t address 401(k) contributions tied to student loan repayments, emergency savings accounts, automatic enrollment rules, nor the 50% “saver’s match” – but will instead focus on a select few provisions that have already taken effect or will take effect shortly.
“There are a lot of pages, but it’s not going to cover everything that folks would have hoped or demanded be covered,” stated the Treasury advisor.
A Treasury representative did confirm that this “grab bag” guidance is a top issue for the agency, and it intends to issue it shortly– slated for release ahead of other proposed rules that the agency has been working to finalize prior to year-end.
Employers and administrators should continue to actively monitor IRS alerts and guidance, and should discuss all updates and anticipated changes with their ERISA counsel – particularly in case any of the forthcoming guidance impacts any design, documentation and/or administrative changes that have been made or are in the works for near-term implementation.