Brian Tiemann
Subscribe to Brian Tiemann's PostsBrian J. Tiemann counsels public and private companies on a broad range of employee benefit matters, including matters related to pension plans, 401(k) plans and executive and incentive compensation. He advises plan fiduciaries with respect to their fiduciary duties, investment policies and alternative investments. He also advises multinational clients on global employee benefits matters, particularly with respect to global incentive compensation plans. Brian has extensive experience negotiating investment management agreements and service provider agreements. Read Brian Tiemann's full bio.
IRS Says Keep Those Class Exclusions Classy Under Long-Term, Part-Time Employee Rules
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Jan 3, 2024
Posted In Employee Benefits, Retirement Plans
Beginning in 2024, employers and plan sponsors will need to implement new minimum eligibility rules, enacted by the SECURE and SECURE 2.0 Acts, that significantly expand eligibility for long-term, part-time employees to participate in employer-sponsored retirement plans. The new rules require that employers who maintain such plans provide employees who work at least 500 hours...
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Last-Minute Guidance Leaves Little Time for Long-Term, Part-Time Employee Changes
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Dec 20, 2023
Posted In Employee Benefits, Retirement Plans
The Internal Revenue Service (IRS) recently issued new guidance clarifying key aspects of the broadened retirement plan eligibility rule for long-term, part-time employees under the SECURE 2.0 Act. However, with the new rule effective for 401(k) plans beginning January 1, 2024, the guidance leaves employers and plan sponsors very little time to make changes to...
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IRS Announces 2024 Employee Benefit Plan Limits
By Jeffrey Holdvogt, Jacob Mattinson and Brian Tiemann on Nov 10, 2023
Posted In Employee Benefits, Health and Welfare Plans
On November 9, 2023, the Internal Revenue Service (IRS) announced cost-of-living adjustments to the applicable dollar limits for certain health and welfare plan benefits, including those for health flexible spending arrangements and commuter benefit plans, among other important updates. Employers, many of whom are in the midst of or have already completed open enrollment for...
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IRS Announces 2024 Employee Benefit Plan Limits
By Jeffrey Holdvogt, Jacob Mattinson and Brian Tiemann on Nov 1, 2023
Posted In Employee Benefits, Fiduciary and Investment Issues, Retirement Plans
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Employer Student Loan Debt Benefits Following SECURE 2.0
By Jeffrey Holdvogt, Brian Tiemann and Teal Trujillo on Oct 11, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
In December 2022, Congress enacted groundbreaking legislation as part of the SECURE 2.0 Act codifying an opportunity for employers to provide matching contributions within a tax-qualified retirement plan based on their employees’ qualified student loan payments outside the plan. This On the Subject discusses the SECURE 2.0 student loan benefit and other employer options for...
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There’s a Party Going on Right Here! Roth Catch-Up Change Delayed Two Extra Years!
By Sarah L. Engle and Brian Tiemann on Aug 28, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
Yahoo! Let’s celebrate—the IRS gave us more time! On August 25, 2023, the Internal Revenue Service announced an administrative transition period that effectively delays the deadline for adding Roth catch-up contributions under the SECURE 2.0 Act until at least 2026. Specifically, the announcement provides that, until 2026, catch-up contributions will satisfy the requirements under SECURE...
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Just Catching Up? For SECURE 2.0’s Catch-Up Contributions, Age Is More Than Just a Number
By Sarah L. Engle and Brian Tiemann on Aug 15, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
Nearly all employers offer eligible participants the opportunity to make additional catch-up contributions to their retirement plans. However, beginning in 2025, the SECURE 2.0 Act makes so-called “super-catch-up contributions” available to certain employees. Adding this new feature will require employers and their service providers to develop new processes to monitor various ages and limits and...
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SECURE 2.0 Technical Corrections Are on the Way, Eventually
By Sarah L. Engle and Brian Tiemann on Jul 11, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
In an open letter to Secretary of the Treasury Janet Yellen and IRS Commissioner Daniel Werfel, congressional leaders identified several technical errors in the SECURE 2.0 Act that they intend to correct. Although the letter indicates that Congress intends to correct these technical errors and ambiguities in the legislation, it does not address the timetable...
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Just Catching Up? Oops! Congress Clarifies Catch-Up Contributions Are Here to Stay
By Sarah L. Engle and Brian Tiemann on Jul 7, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
Section 603 of the SECURE 2.0 Act requires catch-up contributions made by certain high-wage earners to be made on a Roth basis beginning in 2024. But it also contains one of the most talked about technical errors in the legislation, one that resulted in Congress eliminating all catch-up contributions—for everyone. Not surprisingly, that isn’t quite...
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Just Catching Up? Payroll Challenges Plague Roth Catch-Up Contribution Implementation
By Sarah L. Engle and Brian Tiemann on Jul 5, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
The SECURE 2.0 Act requires participants who earned more than $145,000 in FICA wages in the prior year from their current employer to make all catch-up contributions on a Roth basis beginning in 2024. For many employers, the primary concern is how to integrate the new rule with how payroll deductions for catch-up contributions are...
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