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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    ERISA

Date & Time
  • event Date

    Tuesday, October 15, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$347.00
CLE
ALL

This CLE webinar will provide employee benefits counsel, plan sponsors, and administrators guidance on recently issued IRS final regulations implementing many of the SECURE 1.0 Act and SECURE 2.0 Act changes to the rules governing required minimum distributions (RMDs); and newly issued proposed regulations that are intended to further clarify certain SECURE 2.0 Act changes to the RMD rules. The panel will discuss key components of the final regulations and changes made to retirement account distributions and RMDs by the SECURE Acts.

Faculty

R. Sterling Perkinson
Partner
Kilpatrick Townsend & Stockton LLP

Mr. Perkinson focuses his practice on employee benefits and executive compensation. He collaborates with plan sponsors, fiduciaries and plan service providers to help them achieve their objectives while reducing their risk.

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Sanyam D. Parikh
Counsel
Kilpatrick Townsend & Stockton LLP

Mr. Parikh creatively resolves his clients’ challenging executive compensation and employee benefits issues. His practice often involves navigating the complex executive compensation rules peppered throughout the tax code in Sections 409A and 280G among many others, ERISA’s rules governing employee benefit plans, its fiduciary rules and its plan assets regulations, the Affordable Care Act, and COBRA. Mr. Parikh was named a “Legal Elite” in 2024 and the three years immediately preceding for Employment Law by Business North Carolina magazine. He was recognized as a North Carolina "Rising Star" in 2024 and the three years immediately preceding in the area of Employee Benefits by Super Lawyers magazine.

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Description

On July 18, 2024, the IRS finalized regulations governing RMDs to reflect changes made by the SECURE Acts. Counsel assisting plan sponsors and administrators must recognize key issues stemming from these final regulations and ensure compliance for qualified plans, IRAs, tax-deferred annuities, and 457(b) plans.

The final regulations include certain revisions that reflect the changes implemented in SECURE 2.0 Act, including increasing the age for required beginning dates, exempting Roth accounts from lifetime distributions, reducing RMD excise taxes, and expanding lifetime income availability; and providing clarification on non-eligible designated beneficiaries who are subject to both the 10-year rule and the "at least as rapidly" rule along with other critical provisions.

The new proposed regulations focus on addressing additional RMD issues under the SECURE 2.0 Act, such as (1) the special spousal election; (2) calculation of the partial annuity aggregation rule; (3) distributions from designated Roth accounts not subject to lifetime RMD payments; (4) treatment of corrective distributions of missed RMD payments; and (5) distributions to trust beneficiaries.

Any failure to take an RMD carries stiff penalties: a 50 percent excise tax was imposed for missed RMDs in years 2022 and prior. From 2023 onward, the excise tax is reduced to 25 percent on insufficient or late RMD withdrawals, and it is further lowered to 10 percent if the RMD is corrected timely. Understanding when distributions must be made is critical for those participating in these plans.

Listen as our panel discusses key components of the final and proposed regulations and changes made to retirement account distributions and RMDs by the SECURE Acts. The panel will also offer techniques for rectifying missed RMDs and relevant administrative considerations.

Outline

  1. Final RMD regulations
  2. New Proposed RMD regs and SECURE 2.0
  3. IRAs
    1. Rules for inherited IRAs
    2. Penalty-free withdrawals
    3. Comparison to other qualified plans
  4. RMDs
    1. Beginning dates
    2. How beneficiary RMDs are determined
    3. Resolving missed RMDs
  5. Minimizing taxes paid on distributions

Benefits

The panel will review these and other critical issues:

  • Key provisions of the final and proposed RMD regulations
  • RMD rules and requirements following the SECURE Acts
  • IRA distribution rules for beneficiaries following the SECURE Acts
  • Distribution rules for IRAs vs. other qualified plans
  • Rectifying missed RMDs