Insights
Mike Hadley Comments on Key SECURE 2.0 Guidance with Tax Notes
Davis & Harman Partner Mike Hadley was featured in the Tax Notes article, “IRS Answers Calls for Additional SECURE 2.0 Guidance,” where he discussed proposed guidance for SECURE 2.0 provisions regarding age 60-63 super catch-up contributions offered by the Internal Revenue Service (IRS).
Tax Notes reported that the Treasury Department and IRS released guidance on the SECURE 2.0 Act provisions regarding automatic enrollment and catch-up contributions. The article notes that, in August 2023, the IRS gave employer retirement plans a two-year administrative transition period ending December 31, 2025, to comply with the new Roth designation rule.
The proposed regulations also clarify the application of the “super catch-up” contribution enacted by SECURE 2.0, which provides a higher contribution limit for employees ages 60 to 63 beginning in 2025. The super catch-up contribution rule is optional for employers to incorporate into their plans, according to the IRS’s interpretation in the proposal.
Mike Hadley was quoted to say that this was a key thing that benefits industry professionals were waiting to have confirmed. Hadley continued to say that a number of plans have not yet implemented the super catch-up for 2025, although he expects that over time most plans will.
To read the article, click here