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Tax Talk - Spring 2024

In this issue of Tax Talk, Spectrum updates you on important compliance deadlines for defined contribution plans and some considerations for retirement plan contributions in 2024.

Upcoming Compliance Deadlines

April 1st   

  • Electronic filings of Form 1099-R for 2023 distributions are due to the IRS. (The deadline is March 31, which falls on the weekend in 2024. The IRS provides that dates that fall on a Saturday, Sunday or holiday are delayed until the next business day.)

April 15th 

  • Deadline for corrective distributions of excess deferral amounts under Internal Revenue Code Section 402(g) to participants.

  • Deadline for the first 2024 minimum funding quarterly installment payment for DB plans that had a funding shortfall in 2023—i.e., due 15 days after the last plan-year quarter-end.

  • Employer contributions are due to the plan’s trust for C corporations with a December 31 fiscal year-end in order to take deductions with no corporate tax extension.

April 29th

  • Deadline for sponsors of single and multiemployer DB pension plans to send their annual funding notice to participants, beneficiaries, and labor organizations representing participants. (The notice must be provided no later than 120 days after the close of the plan year, and 2024 is a leap year.)

  • Small plans—i.e., those covering fewer than 100 participants—must provide the notice by the IRS filing due date of the plan’s Form 5500; the notice takes the place of the summary annual report for a DB plan.

April 30th

  • Reconciliation filing and payment for the 2023 comprehensive Pension Benefit Guaranty Corporation premium due to the PBGC for DB plans that filed an earlier estimated variable rate premium in the October 16, 2023, comprehensive filing.

May 15th

  • Deadline for participant-directed DC plans to supply participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses charged to individual plan accounts during first quarter of this year. (Due 45 days after the end of the quarter.)

June 28th

  • Deadline for retirement plans with publicly traded employer securities to file their Form 11-K annual report—i.e., by 180 days after the end of the retirement plan year.

June 30th

  • Deadline for corrective distributions for failed ADP/ACP tests to highly compensated employees (HCEs), to avoid a 10% excise tax on the employer for EACA plans. (June 30 falls on a weekend in 2024. There is an open question as to whether the IRS rules for extending deadlines that fall on a non-business day apply to corrective distribution deadlines.)

Increasing Contributions Over Time
It’s important to remind your plan participants to periodically consider increasing their retirement plan contributions. Some retirement plans may start with an automatic enrollment for a new employee and a default contribution of 3%, and automatically increase that contribution rate annually over time to reach a specific contribution threshold, for example 10%. Other plans may not include these automatic features or may offer automatic enrollment but with a default contribution rate that remains static at 3%.

As plan design varies, now, during tax season, is a good time for retirement plan participants to revisit their financial picture, consider what portion of their income they may be able to set aside for retirement, and potentially what percentage they may be able to increase their retirement plan contribution by and when.

An Overview of 2024 Contribution Maximums

  • In 2024 the contribution limit for employees who participate in 401(k), 403(b), and most 457 plans is $23,000, up from $22,500 in 2023.
     
  • The catch-up contribution limit for employees aged 50 and over who participate in 401(k), 403(b), and most 457 plans remains $7,500 for 2024.
     
  • As a result, participants in 401(k), 403(b), and most 457 plans who are 50 and older can contribute up to $30,500 in 2024.

We Are Here to Help
As always, Spectrum is here to support you and your employees. Please contact your Spectrum representative for additional information or assistance in meeting some of these important compliance deadlines or if you have any questions about retirement plan contributions.


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ERISA Workplace Retirement Plan Limits

The federal government annually publishes updated qualified retirement plan limits, which impact the contributions, benefit accruals, and compliance of ERISA covered qualified retirement plans. The below tables summarize the most significant changes in recent history.


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