IRS Issues SECURE 2.0 Guidance

On December 20, 2023, the IRS released Notice 2024-2, Miscellaneous Changes Under the SECURE 2.0 Act of 2022. The so-called “Grab Bag” Notice provides guidance to multiple provisions of the SECURE 2.0 Act of 2022—including Sections 101, 102, 112, 113, 117, 326, 332, 348, 350, 501, 601 and 604. These sections include provisions impacting the following retirement plan topics.

  • Automatic enrollment

  • Tax credit for small employer plan start-up costs

  • Military spouse eligibility credit for small employers

  • Financial incentives for contributing to a plan

  • Contribution limits for SIMPLE plans

  • Exception to the tax on early distributions from qualified plans for individuals with a terminal illness

  • Mid-year replacement of a SIMPLE retirement plan with a safe harbor 401(k) plan

  • Cash balance plan provisions

  • Safe harbor for correction of employee elective deferral failures

  • Plan amendments

  • SIMPLE and SEP Roth IRAs

  • Optional treatment of employer contributions or nonelective contributions as Roth contributions