Teal Trujillo
Subscribe to Teal Trujillo's PostsTeal Trujillo focuses her practice on employee benefits and executive compensation matters for public and private companies. She regularly leads due diligence and advises on liability related to retirement plans, health and welfare plans and executive compensation in stock purchase and asset purchase transactions. Read Teal Trujillo's full bio.
A Q&A and More Delay: IRS Begins to Issue Clarifying Guidance on SECURE 2.0 Provisions
By Jeffrey Holdvogt, Lisa Loesel and Teal Trujillo on Apr 4, 2024
Posted In Employee Benefits, Retirement Plans
In late December 2023, the Internal Revenue Service (IRS) issued Notice 2024-2 (the Notice), providing guidance on key provisions of the SECURE 2.0 Act of 2022 (SECURE 2.0). SECURE 2.0, which was passed in December 2022, includes more than 90 provisions affecting US retirement plans, many of which are specifically aimed at enhancing savings opportunities...
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Funding Employer-Sponsored Group Health Coverage: The Group Captive Solution
By Alden Bianchi, Lisa Kaderabek and Teal Trujillo on Dec 13, 2023
Posted In Employee Benefits, Health and Welfare Plans
The enactment of the Affordable Care Act in 2010 led to a sharp increase in employers self-funding their group health insurance plans, with the market tripling in size in the decade that followed. While larger employers can self-fund their group medical coverage in a relatively efficient manner, it does not work well for smaller employers....
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Employer Student Loan Debt Benefits Following SECURE 2.0
By Jeffrey Holdvogt, Brian Tiemann and Teal Trujillo on Oct 11, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
In December 2022, Congress enacted groundbreaking legislation as part of the SECURE 2.0 Act codifying an opportunity for employers to provide matching contributions within a tax-qualified retirement plan based on their employees’ qualified student loan payments outside the plan. This On the Subject discusses the SECURE 2.0 student loan benefit and other employer options for...
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Webinar Replay: SECURE 2.0 and the Impacts of Employer Matching for Student Loan Payments
By Jeffrey Holdvogt and Teal Trujillo on Sep 20, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
Student loan debt is set once again to impact millions of American workers. Fortunately, starting next year, employers will have new ways to help employees navigate student loan debt. Provisions of the SECURE 2.0 Act will allow employers to provide employer-matching contributions based on their employees’ qualified student loan repayments outside the plan. In this...
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SECURE 2.0: The Impacts of Employer Matching for Student Loan Payments
By Jeffrey Holdvogt and Teal Trujillo on Sep 6, 2023
Posted In Employee Benefits, Retirement Plans, SECURE 2.0 Act
Following the US Supreme Court’s rejection of substantial portions of the Biden administration’s plans for student loan debt relief, and with the end of the student loan repayment moratorium in sight, student loan debt is set once again to impact millions of American workers. Fortunately, starting next year, employers will have new ways to help...
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IRS Opines on the Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policies
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Aug 10, 2023
Posted In Employee Benefits, Health and Welfare Plans
In light of recent Internal Revenue Service (IRS) guidance, employers should carefully examine any supplemental health plan, program or arrangement (which may or may not claim to leverage fixed indemnity insurance) that promises substantial payroll tax savings. In a legal advice memorandum, the IRS’s Office of Chief Counsel addressed and rejected the claimed tax treatment...
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Fixing the ACA’s Family Glitch
By Alden Bianchi and Teal Trujillo on Jul 13, 2023
Posted In Employee Benefits, Health and Welfare Plans
The “family glitch” was a regulatory oddity of the Affordable Care Act (ACA). It required the affordability of an employer-sponsored health plan to be determined based solely on the cost of the plan to an individual employee, disregarding the costs to add family members to a plan. This resulted in many families being ineligible for...
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IRS Issues Reminder that Claims Under Health and Dependent Care FSAs Must Be Substantiated
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Jun 1, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Internal Revenue Service (IRS) recently issued a Chief Counsel Advice memorandum to remind sponsors of health and dependent care flexible spending arrangements (FSAs) about their responsibility to adequately substantiate claims in order to receive favorable tax treatment under Section 125 of the Internal Revenue Code (the Code). The IRS emphasizes that the standards for...
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Preparing for the End of the COVID-19 Emergency: Deadline Tolling
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on May 18, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April 10, 2023, President Biden signed a resolution moving up the end of the NE to April 10, 2023 (the PHE ended...
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Tri-Agencies Address Preventive Services Coverage in the Wake of Braidwood
By Sarah Raaii, Jacob Mattinson, Alden Bianchi and Teal Trujillo on May 5, 2023
Posted In Employee Benefits, Health and Welfare Plans
The US Departments of Labor, Health and Human Services, and the Treasury (the Departments) have released a series of Frequently Asked Questions (FAQs) in response to Braidwood Mgmt. Inc. v. Becerra, a recent case that invalidated a portion of the Affordable Care Act (ACA) preventive services mandate. The FAQs aim to address inquiries from stakeholders,...
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