EBIA Weekly Newsletter

IRS Audit Guidelines Provide Some Documentation Relief for Substantiating 401(k) Plan Safe Harbor Hardship Distributions


   March 9, 2017

Memorandum for Employee Plans (EP) Examinations Employees: Substantiation Guidelines for Safe-Harbor Hardship Distributions from Section 401(k) Plans, TE/GE-04-0217-0008 (Feb. 23, 2017) Available at https://www.irs.gov/pub/foia/ig/spder/tege-04-0217-0008.pdf The IRS has a released a memorandum to its Employee Plans (EP) examination employees that establishes audit guidelines for substantiating safe harbor hardship distributions from 401(k) plans. A hardship … Read More


Transit Plan May Require Use of Debit Card Even If Cash Reimbursement Is Permissible 


   March 2, 2017

Information Letter 2016-0085 (Oct. 5, 2016) Available at https://www.irs.gov/pub/irs-wd/16-0085.pdf The IRS has released an information letter about a qualified transportation plan that discontinued cash reimbursement of transit expenses and began requiring that those expenses be paid using an electronic debit card. As the letter explains, qualified transit plans are permitted to offer cash … Read More