Jeffrey Holdvogt
Subscribe to Jeffrey Holdvogt's PostsJeffrey (Jeff) M. Holdvogt regularly counsels public and privately held companies and tax-exempt organizations on a wide range of employee benefits matters. These include the design and administration of complex pension, 401(k) and 403(b) plans, nonqualified and executive deferred compensation arrangements, fiduciary and plan investment issues under the Employee Retirement Income Security Act (ERISA), internal compliance reviews and voluntary correction filings, and benefit plan matters arising from mergers and acquisitions, as well as other ongoing day-to-day retirement and executive compensation issues. Read Jeff Holdvogt's full bio.
DOL Report on Quality of Independent Plan Audits Shows that Plan Sponsors Must Continually Monitor Plan Compliance
By Jeffrey Holdvogt on Jun 18, 2015
Posted In Retirement Plans
The Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL) recently released “Assessing the Quality of Employee Benefit Plan Audits,” a comprehensive report reviewing the quality of audit work performed by independent qualified public accountants with respect to financial statement audits of employee benefit plans covered by the Employee Retirement Security Act...
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DOL Provides Greater Flexibility for Distribution of Annual Participant Fee Disclosure Effective Immediately
By Diane Morgenthaler, Jeffrey Holdvogt and Maggie McTigue on Apr 23, 2015
Posted In Employee Benefits, Employment
New guidance by the U.S. Department of Labor provides defined contribution plan administrators with additional flexibility to extend the 12-month period to a 14-month period for distribution of the required annual fee disclosure to plan participants and beneficiaries. Read the full article.
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IRS Permits Puerto Rico-Qualified Plans in U.S. Group Trusts, Extends Deadline for Certain Puerto Rico Spin-Offs
By Jeffrey Holdvogt on Feb 10, 2015
Posted In Retirement Plans
The U.S. Internal Revenue Service (IRS) recently issued Revenue Ruling 2014-24, which expressly permits retirement plans that are tax qualified only in Puerto Rico (Puerto Rico-only plans) to continue to pool assets with U.S.-qualified plans in Revenue Ruling 81-100 group trusts (group trusts) now and in the future. The ruling is welcome relief for Puerto...
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Join McDermott Partners at a Webinar on TOP IRS and DOL Audit Issues for Retirement Plans
By Jeffrey Holdvogt on Jan 29, 2015
Posted In Employment, Labor, Retirement Plans
Tuesday, February 10, 2015 12:30 – 1:30 pm EST Please join McDermott Will & Emery for a complimentary webinar discussing key issues retirement plan sponsors should take into account when establishing and maintaining internal controls based on the compliance requirements Internal Revenue Service (IRS) and U.S. Department of Labor (DOL) agents review when they conduct...
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You’ve Acquired a New Qualified Retirement Plan? Time for a Compliance Check
By Jeffrey Holdvogt on Nov 12, 2014
Posted In Retirement Plans
In connection with a merger or acquisition, an acquiring company may end up assuming sponsorship of a tax-qualified retirement plan that covers employees of the acquired company. This article provides a brief summary of some key issues that a company should focus on to ensure that the numerous administrative and fiduciary requirements involved in maintaining...
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PBGC Coverage May No Longer Apply to Puerto Rico-Only Qualified Retirement Plans
By Jeffrey Holdvogt on Oct 22, 2014
Posted In Retirement Plans
Employers that sponsor defined benefit qualified retirement plans benefiting only Puerto Rico employees should be aware that Pension Benefit Guaranty Corporation (PBGC) coverage may no longer apply. Last year, the PBGC withdrew old prior opinion letters (Opinion Letters 77-172 and 85-19) regarding PBGC coverage in Puerto Rico and Guam. Those opinion letters articulated the PBGC’s...
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Tax Prepayment Window Closes on October 31, 2014, for Puerto Rico Retirement Plans
By Jeffrey Holdvogt on Oct 7, 2014
Posted In Retirement Plans
On July 1, 2014, Puerto Rico adopted new legislation (Tax Act 77), which provides a window from July 1, 2014 – October 31, 2014, for participants in Puerto Rico retirement plans to prepay at reduced rates Puerto Rico income tax on the value of accrued benefits. On August 6, the Puerto Rico Treasury Department issued...
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View From McDermott: Top IRS and DOL Audit Issues for Retirement Plans
By Jeffrey Holdvogt on Sep 4, 2014
Posted In Retirement Plans
Every year the Internal Revenue Service (IRS) and Department of Labor (DOL) conduct thousands of audits of employee benefit retirement plans. While IRS audits focus on compliance with the Internal Revenue Code, and DOL audits focus on violations of the Employee Retirement Income Security Act of 1974, as amended (ERISA), a review of these audits...
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PBGC Coverage May No Longer Apply to Puerto Rico-Only Qualified Retirement Plans
By Jeffrey Holdvogt on Aug 14, 2014
Posted In Retirement Plans
Employers that sponsor defined benefit qualified retirement plans benefiting only Puerto Rico employees should be aware that Pension Benefit Guaranty Corporation (PBGC) coverage may no longer apply. Last year, the PBGC withdrew old prior opinion letters (Opinion Letters 77-172 and 85-19) regarding PBGC coverage in Puerto Rico and Guam. Those opinion letters articulated the PBGC’s...
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New IRS Program for Delinquent Form 5500 Filers of Non-ERISA Plans
By Jeffrey Holdvogt, Patrick Ryan and Todd Solomon on Jun 17, 2014
Posted In Retirement Plans
The Internal Revenue Service recently established a one-year pilot program that provides plan administrators and plan sponsors of certain non-ERISA and foreign plans subject to the annual Form 5500 reporting requirements relief from penalties under the Internal Revenue Code. The penalty relief is temporary and expires on June 2, 2015. Read the full article.
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