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Federal Appeals Court Rejects Equitable Remedies When SPD Promises More Generous Benefits Than Pension Plan Document

A federal appeals court has handed down the first significant decision to interpret the Supreme Court’s recent ruling on ERISA remedies.  In CIGNA Corp. v. Amara, the Supreme Court suggested three methods by which participants might enforce the terms of an SPD that promises greater benefits than the underlying plan document:  estoppel, reformation, and surcharge.  In Skinner v. Northrop Grumman Retirement Plan B, participants tested two of these methods.  The Ninth Circuit rejected both.

COMMON PLAN MISTAKES: Miscalculating Matching Contributions

Miscalculating an employer matching contribution is one of the most common mistakes in the administration of a Section 401(k) plan.  This mistake often occurs because the plan sponsor calculates the matching contribution using an incorrect timing assumption—for example, a pay-period basis, rather than an annual basis.

IRS Proposes Methods for Valuing Employer Health Coverage

In order to implement several provisions of health care reform, the Affordable Care Act (“ACA”) will require “large employers” (those with 50 or more full-time employees) to determine whether their employer health plans provide “minimum value.”  In Notice 2012-31, the IRS has proposed three different methods by which an employer might make this determination.

IRS Announces 2013 Amounts for HSAs and HDHPs

In Revenue Procedure 2012-26, the IRS has announced the 2013 inflation-adjusted amounts for health savings accounts (“HSAs”) and qualifying high deductible health plans (“HDHPs”), all as determined under Section 223 of the Internal Revenue Code.

Ready Reference Chart: W-2 Reporting of Employer Health Coverage

Employers that issued 250 or more w-2s for 2011 must report the value of any employer-provided health coverage on their employees’ 2012 W-2s.  The chart found at this link shows the types of coverage that should be included in that reporting, the types that should not be included, and those for which reporting is optional.

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