In a recently issued procedural notice, the Small Business Association (“SBA”) addressed a lingering question of borrowers and lenders related to the Paycheck Protection Program (“PPP”) process: What procedures are required for changes of ownership of an entity that has received PPP funds? The notice, issued on October 2, describes when change of ownership is considered to have occurred and what impact such change has on a PPP borrower’s responsibilities under the program......By: Fraser T...
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On September 24, 2019, the U.S. Department of Labor announced a final rule to make 1.3 million American workers newly eligible for overtime pay. The new rule is effective January 1, 2020 and includes the following changes to overtime rules: Raise...By: Fraser Trebilcock
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Proper characterization of workers as independent contractors or employees is a question that crosses many areas of substantive state and federal law, prominently federal tax law. IRS Publication 15-A, Employer’s Supplemental Tax Guide (2020) (Dec...By: Fraser Trebilcock
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Deadline Coming Up for Calendar Year Plans to Submit Medicare Part D Notice to CMS- As you know, group health plans offering prescription drug coverage are required to disclose to all Part D-eligible individuals who are enrolled in or were seeking...By: Fraser Trebilcock
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December 19, 2019, Congress finally passed the Setting Every Community Up for Retirement Enhancement Act (i.e., the “SECURE Act”), and President Trump is expected to sign it. The SECURE Act was previously passed by the U.S. House of Representatives...By: Fraser Trebilcock
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The Internal Revenue Service (“IRS”) has just released the Final Forms and Instructions for 2019 information reporting by employers and other entities under Internal Revenue Code sections 6055 and 6056....By: Fraser Trebilcock
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Statements to Individuals- The Internal Revenue Service (“IRS”) has extended the deadline for 2019 Information Reporting by employers (and other entities) to individuals under Internal Revenue Code sections 6055 and 6056 by just over a month....By: Fraser Trebilcock
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The IRS has just released its 2020 annual inflation adjustments, in which it announced that the dollar limitation under Code section 125 on voluntary employee salary reductions for contribution to health flexible spending arrangements (health FSAs)...By: Fraser Trebilcock
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Pursuant to a 2018 Executive Order, the Department of Labor released proposed regulations this week which would expand an employer’s ability to provide ERISA disclosures electronically. These rules do not replace existing guidance, but instead add an...By: Fraser Trebilcock
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Patient-Centered Outcomes Research Institute (PCORI) Fee/Comparative Effectiveness Fee- Please let this serve as a reminder that the PCORI fee is due by July 31st and must be reported on Form 720. The fee is used to partially fund the...By: Fraser Trebilcock
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