Forfeitures: Changing the Rules of the Game for Retirement Plans

The US Department of the Treasury and the Internal Revenue Service recently issued proposed regulations on the use of forfeitures by tax-qualified retirement plans. The proposed changes provide welcome clarity for plan sponsors but may require revisions to plan administration and legal plan documents.

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Diane Morgenthaler
Diane M. Morgenthaler focuses her practice on employee benefits and executive compensation. She represents clients in matters before the US Internal Revenue Service, the Department of Labor and the Pension Benefit Guaranty Corporation. Diane serves as employee benefit counsel to Fortune 500 corporations and other global corporations, and represents both public and private clients. She regularly designs and implements a variety of employee benefit plans and programs. Diane has extensive experience in employee benefit issues involved in acquisitions, reorganizations and divestitures and in the design of employee benefits plans following such transactions. She also advises clients in matters involving multi-employer withdrawal liability, fiduciary liability and benefit claims.


Dan O’Neil
Dan O’Neil advises clients on a wide range of benefits and compensation matters. He focuses his practice on employee benefits and executive compensation issues arising in corporate transactions. Dan has experience with employee benefit and executive compensation due diligence, negotiation of the related provisions in transaction agreements and assists clients with issues relating to Sections 280G and 409A of the Code. Dan is also experienced in a wide range of tax and benefits issues, including day-to-day retirement plan compliance, ERISA fiduciary matters, prohibited transactions and employee stock ownership plans (ESOPs). Read Dan O’Neil's full bio.


Jeffrey Holdvogt
Jeffrey (Jeff) M. Holdvogt advises clients regarding a wide range of employee benefits matters. He focuses primarily on the design and administration of complex pension, defined contribution and executive deferred compensation arrangements. Jeff counsels privately and publicly held corporations on ongoing day-to-day retirement and executive compensation issues, as well as employee benefits design and transition matters arising from corporate mergers, acquisitions and divestitures. Read Jeff Holdvogt's full bio.

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