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Treasury and IRS Announce 2003-2004 Priority Guidance Plan for Employee Benefits Issues

Client Alert | 1 min read | 12.22.03

The Treasury Department's Office of Tax Policy and the IRS have announced their 2003-04 priority guidance plan. This is a list of the items that have been identified as the top areas in which guidance will be provided.

In the retirement benefit area, the list includes guidance on phased retirement arrangements; proposed nondiscrimination regulations for cash balance plans (unless Congress enacts a moratorium on the issuance of such regulations-see V, below); minimum required distribution regulations for qualified plans, guidance on Code Section 403(b) tax-deferred annuity plans, final regulations on S corporation ESOPs, guidance on the Code's age discrimination rules for qualified plans, anti-cutback guidance, guidance on use of electronic technologies for various retirement plan transactions. and model provisions for Code Section 457(b) deferred compensation arrangements.

In the areas of executive compensation, health care and other benefits, the list includes guidance on elections between taxable and nontaxable benefits; guidance on "restricted property" under Code Section 83; guidance on disability payments; guidance on health reimbursement accounts (HRAs); guidance on debit cards; guidance on health care provider incentive payments; and a revenue ruling under Code Section 4980B on Medicare entitlement as a second qualifying event under COBRA.

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Client Alert | 4 min read | 10.30.26

Two Wrongs Don’t Make a Right: GAO Sustains Protest Where Agency Tried to Fix PIA Violation with a Second PIA Violation

Recent sustain decisions by the U.S. Government Accountability Office (GAO) in Fluor Federal Solutions, LLC and Reliance Test & Technology send a clear message: when an agency tries to fix a Procurement Integrity Act (PIA) violation by committing a second one, the cure can be just as fatal as the disease. The cases involved the U.S. Air Force’s $1.8 billion procurement for O&M services at Elgin Air Force Base. During discussions, the Air Force inadvertently released a pricing overview slide with all offerors’ bottom-line evaluated costs to Reliance Test & Technology, which immediately notified the agency of the error. In response, the Air Force decided to level the playing field by providing the same information to all the other offerors in the procurement, stating, “[o]fferors may consider this disclosure in their [final proposal revision].”...