August 19, 2025 • 35 mins
On this episode, we’ll look into some of the biggest changes in the world of compensation and benefits including those from the One Big Beautiful Bill Act (OBBBA), as well as some of those from the first and second SECURE Acts. We welcome Dave Graf, a leader in the Private Client practice at Forvis Mazars who specializes in qualified retirement plans.
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Episode Transcript
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(00:00):
On this episode, we'lllook into some of the biggest changes
in the world of compensation and benefits,including those from the OB three,
as well as some of those from the firstand second SECURE acts.
We welcome Dave Graf,a leader in the Private Client practice
here at Forvis Mazars who specializesin qualified retirement plans,
to join me to talk about this subject,which is very near and dear to my heart.
(00:22):
From your onestop for tax updates and analysis.
I'm Devin And I'm Iris.
It's Tuesday, August 19thand this is Tackling
Tax with Forvis Mazars.
(00:49):
Before we get startedwith our much-anticipated guest,
we always like to start our showwith what we call our Fast Four stories
that we thinkmight be most impactful to you.
So let's dive right into our FastFour stories of the week.
For our first
story of the day, we're going to tackletechnical correction.
(01:10):
So, a slew of technical correctionsto the OB three,
or OBBBA, could be expectedin the coming months.
Members of Congresshave returned to their states
and districts as Congress is on recessuntil September 2nd,
with many addressing concernsof their constituents about the act.
Senator James Lankford of the SenateFinance Committee was quoted saying,
(01:32):
whatever bill goes out, no matter how longor short it is, there will be something.
You'll go, oh,that was an unintended consequence of it.
Especially with the complexity of tax law.
So the number of scope of these technicalcorrections will largely be determined
once the JCT publishes its Blue Bookcovering the Act.
You know,I certainly look forward to the Blue Book.
(01:53):
I still have occasional nightmaresabout the Tax Cuts and Jobs
Act and assume that you've probablyhad a similar experience.
Iris. Oh, you know it.
It's a lot to dig through,but also some really good guidance there.
So this just likeTCJA was a major piece of tax legislation
so it's going to take years beforemost of the wrinkles are ironed out.
(02:16):
Absolutely.
For our second story
we're going to talk about the revolvingdoor at the IRS commissioner post.
So, the IRS is in search of its eighthIRS commissioner
for 2025,after President Trump removed Billy Long,
who only served in the positionfor less than two months.
Wait, sorry, did I hear eighth?
(02:39):
Is that right? The eighth commissioner?
Yeah, you certainly did.
And considering that this has historicallybeen a five-year appointment,
seeing this many commissioners in a singleyear is certainly out of the norm.
Now, moving forward, Scott Bessent, Secretary of the Treasury,
has stepped into the roleas acting commissioner
while he and others begina search for the eighth
(03:01):
and hopefully finalIRS Commissioner of 2025.
Now, Long was not the onlynotable departure; as the head
of the Department of Justice Tax Division,Karen Kelly has also stepped down.
Now, this really shouldn'tcome as too much of a surprise
because last monthit was announced by DOJ officials
that they have a planto eliminate the tax division
(03:24):
and relocate its attorneysto other divisions within the department.
So, it's not necessarily a big surprise.
And I also don't necessarily anticipatesomeone filling that role.
Well, our show is Tackling Tax,but here we also tackle tariffs.
So, another week,another update on tariffs.
To start,the US and China have agreed to pause
tariff hikes on each otherfor an additional 90 days,
(03:47):
halting a significant tariff increaseby both sides.
Reciprocal tariffshave also gone into effect on dozens
of countries, with ratesranging from 10 to 41%.
Additionally,the de minimis exception will end
for all countries effective August 29th.
Iris,if you don't mind if I interject quickly.
The de minimis exception,can you maybe provide some context
(04:09):
on what that is and what this means?
Sure, historically, importedgoods valued at or under that $800 mark
have fallen under a de minimis exceptionfrom customs clearance and duties.
So, up until now, the exceptionhas been in place for global imports,
with the exception of those from China,which was lifted earlier in May.
(04:29):
So, however, starting August 29th,all imports, regardless of their value,
will be required to go through customsclearance and face duty rates.
Last but not least,let's talk about the new provisions,
no tax on tips and overtime.
So, the IRS recently announcedthat there's not going to be any changes
in 2025 to withholding tables or tocertain information returns for that year.
(04:53):
They primarily stated that they're
not going to be making these changesbecause they want to avoid disruptions
to tax filing
and also give the IRS enough timeto implement these changes effectively.
I mean, with the Billy Long news,I understand why
they probably want that additional time.
So, this announcement also saidthat they are working
on guidance for 2026.
And that's going to include,you know, new withholding tables
(05:17):
and also how employers should report tipsand overtime to their employees.
So, the IRS is going to coordinatewith employers, payroll
providers and tax professionals to helpkind of ensure a smooth transition here.
On another front,
Democratic lawmakers from Nevadahave shared a letter with the Treasury
and IRS, urging themto support a number of changes
(05:37):
to these laws onno tax on tips and overtime.
Basically asking for a lot of things but
they include auto gratuitiesas qualified tips,
which are currently excludedunder the provision.
What is an auto gratuity?
I mean, I think that probably could bea lot of things, right?
Yeah.
So the new law requiresthat tips be qualified
(06:00):
tips for this purpose of the deduction.
They have to be voluntary.
So, if we have somethinglike a service fee or automatic gratuity
where there's like a set percentagethat’s automatically charged
to your bill, typicallywhen you have parties of a certain size,
that's not considered voluntaryin this case.
And so,those service charges are not, and auto
(06:23):
gratuities are not,going to be deductible as a qualified tip.
Now the Nevada lawmakershave also put a request in
to make the provision permanent,as it currently is set to expire in 2028.
They've also asked to have
a more broad definition of occupations
that are applicable to claim this,the tips deduction.
(06:46):
And additionally,and I found this one important,
they've also asked for joint filersto be able to claim $25,000 each.
Currently, it's capped at $25,000
in total, regardlessif you're a single filer or joint filer.
So, kind of like we have with overtime,where you have $12,500 per person,
up to $25K when you're filing joint,they want to see that here.
(07:08):
So the cap would actuallybe $50K for joint filers.
This segment we call Planning Insightswhere we examine
current events in the tax worldand some of the resulting strategies.
Today's insight, as I had mentionedearlier, is going to be on a topic near
(07:29):
and dear to my heart,and that's because it's my primary area
of specialty, Comp and Ben.
And that's particularly in the moreonerous rules that govern executive comp
and non-qualified deferred comp,like 409A and 280G
and a bevy of other areas that fallunder that Comp and Ben umbrella.
Now, one area that I rarely touchis that of qualified plans.
(07:51):
But fortunately, the firmhas a very strong practice in this area,
which grew even stronger recently
with the addition of our guestfor today's episode, Dave Graf.
Dave, welcome to Tackling Tax.
Devin, thank you very much.
It's an honor to be here with you guysand look forward to talking qualified
plans, the Internal Revenue Code, ERISA,
(08:14):
all those things that employee
benefit nerds like myselfenjoy talking about.
Yeah, I think you pretty much
have to be a nerd to work in this area,even more so than tax in general.
But, you know, Dave, we work at ForvisMazars, a public accounting firm, but
you have a very nontraditional backgroundand pathway into public accounting.
(08:35):
So I'm wondering,can you maybe give us a little bit
of an introduction about yourself?
You know, how did you kind of grow upin this area, and end up at the firm?
And what are you really doing hereat Forvis Mazars?
Sure. Devin, I'm happy to do so.
And it's kind of funny how,you know, the circle of life works.
Once upon a time, I was
(08:58):
actually working at a big eight
accounting firm in Coopers and Lybrandand going to law school at night
and working my way throughand got finished.
And then the decision was either
stay with Coopersor go out and work at a law firm.
(09:19):
And it was really a tough decision
but I went ahead and chose the path of going to a law firm.
And that's what I've donenow for the last, 40 years, give or take.
And, you know, I got towards
the end of my career,with the law firm that I was
(09:39):
with for over 30 yearshere in Little Rock, Arkansas, and,
you know, I just missed peoplethat kind of had my same values.
And at the top of that list is basically,
you know, the concept of integrityalways trumps economics.
And so,I remember here, 10-15 years ago,
(10:05):
met a gentleman by the name of ChrisDoolittle here in our Little Rock office.
And we got to know one anotherthrough one of his family’s
retirement plansthat had all sorts of trouble with
the IRS, the Department of Labor,
and then we'll throw in the PensionBenefit Guaranty Corporation as well.
(10:27):
All three of those governmental agencies,
and was able to pull his family's plan
out of the ditch and retain the taxqualified status and whatnot.
And so,I reached out to Chris and said, hey,
you know, I'm at the stage in my careerwhere I'd really like to end it
(10:47):
on a good note, and I'd like to do sowith a bunch of guys that are like you.
In other words,a bunch of Chris Doolittle's. And so,
you know,
we talked and talkedand talked some more and the process was,
you know, multiple months, but,
at the end of the day was offeredthe opportunity
(11:10):
to work with the retirement planconsulting group.
And people asked me, Dave,how do you like it over there?
Basically, even though
I'm not technically practicinglaw anymore, I continue to
consult on all sortsof qualified retirement plan issues,
(11:31):
including the preparation of documents
which we just got approved to go to the FTWilliam document package,
which is going to be a real improvementfor us
as far as how we can offer our plansto clients.
But, people askme, well, hey, how's that, what's it
(11:54):
like being essentially a consultantas opposed to an attorney? And
I'm just really blessed,
Devin.
I mean, the way I characterizeit is: within our group of 12,
it's 12 CPAs and one lawyer, as in me.
But, I'm with an all-star group
(12:16):
of professionals that are Hall-of-Famersas human beings.
And so just, tremendously blessed to be a part
of Forvis Mazars and
this is where I'm going to wrap upmy career here, with the team here.
Now, so, you work in retirementplanning on the qualified side.
And that may be the most active areain terms of like, new legislation
(12:41):
and changes and really kind of what'sevolving in the world of Comp and Ben.
So, I was, you know,wanting to talk a little bit about what
you're really seeing specificallywith the SECURE and SECURE 2.0 Acts
and kind of touching on this themeof Roth-ification, you know, what is that?
You know,and also what motivated Congress, to,
(13:03):
you know, put these two huge actsinto place in the first place?
Yeah.
Great question, Devin.
When I first started,
in the area of employee benefits,
and I'm not going to admit how long agothat was because it's been a while.
But, you know, the focus was more
so on, defined benefit pension plansthat companies were there
(13:28):
to kind of guide you through the path of your career.
And then, in additionto giving you a gold watch,
would provide you with a pensionslash annuity for the rest of your life.
And the problem with pension plans,
generally speaking, is that oftentimes,
(13:50):
they're not completely funded for various reasons.
And so you wind up, actually,that type of plan
becoming a money pit on the employer side.
And so
over time,the focus was to, hey, let's shift
this responsibility for retirement.
(14:12):
More so from the employer's responsibilityto the employees.
And so, that was where the adventof the 401(k) plan came in.
And these most recent piecesof legislation,
those are geared towards
adding on to making it moreso
(14:35):
the employee's responsibilityto save for their retirement.
So you've got all sorts of provisionshere.
With the intent to have the employee
shoulder this burdenas opposed to the employer.
And I guess one good thing for me, Devin,
being in the employee-qualified plan worldis that, you know,
(15:00):
I kind of refer to,the SECURE Act and the SECURE 2.0 Act,
as the full employment act for employeebenefit professionals like myself.
Because there's getting ready to be a ton,and I mean a ton, of work
coming up over the next couple of yearsin terms of amendments and restatements,
(15:23):
good-faith amendments, decisions
as to are we going to add a Roth featureso that your highly paid
individuals who make $145,000or more can do catch-up contributions?
I mean, there's
just a ton of
different benefit changescoming down the pike.
(15:45):
Would you say that a lot of these changeswere beneficial
for retirement saving, planning?
You know, as far as I'm aware,if I recall correctly, the SECURE stands
for Setting Every Community Upfor Retirement Enhancement,
and that, this was,kind of, designed to encourage
both employersand employees to participate.
(16:05):
Is that what you've seenbased on the provisions that came out
with the 1.0 and then SECURE 2.0?
Has it really been a good motivation?
Has it added too much complexity?
And, you saidthere's some big stuff coming.
If you, you know, had to sharejust a couple
huge insights that our listenersprobably should be aware
of that are upcoming;what would you want to share?
(16:27):
Yeah, that's a very good question, Devin.
It's kind of funnythat both of these acts,
kind of behind the scenes, the intent wasto, quote unquote, “simplify” things.
And,
I think they kind of whiffed on that.
I mean, the SECURE 2.0
(16:49):
Act has over 93 different
qualified plan changes in there.
And, frankly,a lot of them are pro-employee,
if you would, in terms of various types
of distribution options,which include, like,
a small distributionamount for emergency situations.
(17:13):
There's domestic abuse situations.
Just a lot of little small distributionfeatures.
There's a qualified birthor adoption feature
where, if an individual is about to havea new addition to the family,
that they could pull out up to $5,000from their retirement account
(17:36):
and use that to pay birthor adoption expenses.
And it also gives them the opportunity,
if they so choose, to repay that moneyback to the plan.
So, it would never be taxable.
But, you know, honestly, yeah.
You're not going to see many employersadd any of those features.
(17:58):
But what you are going to seeare a couple features that
are going to surprise people.
And probably at the top of the list
is this whole to-do about long-termpart-time employees.
And, prior to the SECURE Act,
(18:19):
and I've got several hospitalswhere we've got a number of employees
that they don't work1,000 hours in the 12-month period.
And we honestly at the employer-level
like that because we didn'thave to bring them into the 401(k) plan
or make employer matching
(18:41):
contributions or profit-sharingcontributions, for that matter.
But, what the SECURE Act said was that,
hey, if you're a long-term part-time
employee,and back in 2000, under the SECURE Act,
if you had three years of where you had500 or more hours of service,
(19:02):
the employer had to letyou come into the plan
and start making 401(k) contributions.
Now, they were not requiredto make employer
matching or profit-sharing contributions,but they had to let these people
come into the plan for 401(k) purposes.
And then the SECURE 2.0Act expanded on that
(19:26):
and said, hey, you know, it'sno longer going to be three years.
If you've had two years of 500or more hours of service,
you've got to come in for 401(k) purposes.
And that new ruletakes effect in 2025. So,
you know, you're going to have
some people surprised by that.
(19:49):
Another rule that,
frankly,is going to catch a lot of new plans
by surprise is that
and this, again,is effective as of 1/1/2025,
if you have a new plan and an employer
that has more than 10 employees,
(20:11):
they have to automatically enroll
all of their employeesin this new 401(k) plan.
There's no ability to let them decidewhether they want to come in or not.
And with these automatic enrollmentfeatures,
employers are going to have to,
(20:31):
at a minimum, start withholding 3% of pay.
And that goes up each year by a percent
and ultimately could get as highas 15% of pay.
So, you're going to have a lotof additional administration
in terms of, because there'sgoing to be employers that
(20:52):
a lot of
these employeesare not going to want to participate,
but they're going to have to proactivelygo out there and get some sort of piece
of paper back, saying that they don'twant to participate in the plan.
And then of the trifecta,
if you would, of surprisetype changes is one coming
(21:14):
up, Devin, in 2026 and
this is a really convoluted provision,but it's one that was thrown into this
SECURE 2.0 Act, frankly, to generate
some tax revenue and keep people happy.
But it has to do with this Roth-ification,
(21:36):
if you would, of catch-up contributions.
And what the law saysis that any employee, it's
not a highly compensated employee,it's a highly
paid individual, i.e., an HPI
as opposed to an HCI or HCE, I'm sorry.
(21:59):
Well, and what it says is that,
if you want to do catch-up contributions
and just to back up for everybodyon the podcast.
Anyone who's 50 or above
can elect to, in addition to their 402(g)limit of 401(k) contributions,
(22:20):
which is $23,500 here in 2025,
you can do an additional $7,500
if you're 50 or aboveas a catch-up contribution.
And if you're actually between the ages of60 to 63,
you can do an additional
$3,750.
(22:41):
It's called the super catch-up.
And that's $11,250if you fall within any of those years.
But beginning 1/1/2026,
if you make more than $145,000,
your catch-up contributions,you can still do them
but they have to be in the formof a Roth after tax contribution.
(23:05):
So, there are a number of plans out thereright now that do not offer Roth.
And so, if they're going to want to keep
their higher paid people happy.
And again, it starts at $145,000,
not $160,000, which is the quote
unquote “highly compensated employee”threshold.
(23:30):
These contributions will have to be on a Roth after-tax basis.
So, we're getting ready to have a lotof fun here going into the fourth quarter,
because there's going to be a lot of plansthat,
in order to continuewith catch-up contributions
that do not have a Roth provision,they will have to be amended
(23:50):
before January 1st, 2026, to
offer this catch-up feature to theirhigher paid individuals.
And, you know, I've had a lot of questionscome up on this about,
well, okay, we're going to do thisRoth feature.
We're just going to have it apply to these people
(24:11):
that make $145K or more.
And that's a big
absolute no.
If you're going to bring the Roth featurein, it has to be offered
to everybody to avoid any type of nondiscrimination issues.
Well Dave,I'd say that's all incredibly insightful,
(24:32):
but certain people may havea different definition of fun than you.
Yeah, I hear you.
That may be why you work in this area.
Well, Devin, as I mentioned,there were 93 changes
in the SECURE 2.0 Act,and we covered maybe three of them.
So there's 90 left.
But let's go on to some exciting thingsthat are happening in your world,
(24:56):
in particularwith respect to the OB3 legislation.
Yeah, absolutely.
And, you know, therecertainly were not 93 changes in OB3,
but there were a fair amountthat I think are worth discussing.
And, you know,I talked earlier on this episode
about the no tax on tipsand no tax on overtime provisions.
(25:17):
You know,
they were a campaign promise from Trumpthat ultimately did make it into the act.
And they both provide for above-the-linedeductions for individuals
that make certain amounts.
Now there are limits onwho actually can take this deduction
and the amounts that can be taken,
as well as the source of those funds.
(25:39):
If you're going to have tips, for example,
those tips must be limitedto, like, voluntary amounts.
Qualified overtime, on the other hand,is going to be based
on a definitionof the Fair Labor Standards Act.
And so, it's also limited onlyto an actual specific amount of overtime.
(25:59):
And not all overtime wages, but only theadditional amount over their regular pay.
Some things to really know aboutthese provisions that I think stand out
is there's a phase out.
So if you make over $150K or $300K joint,you are going to be phased out.
It's going to be $100per thousand dollars over that limit.
And these deductions are only availablethrough 2028.
(26:22):
Now, again, this is an employee deductionon their tax return.
This is not an income exclusion.
So employers are going to have to reportthese amounts on forms
W-2 and still do all the applicablewithholding, at least in ‘25.
That may change next yearwhen we get these new withholding tables.
But for now, they're still going to haveto report all of these amounts.
(26:46):
And there's going to be additionalreporting from employers.
The problem iswe just don't have any guidance.
So, the employer is going to have to state the occupation
that they're in to ensurethat it's a qualifying occupation.
They're going to have to identify
and provide the actual amount of qualifiedtips or qualified overtime.
There's additional informationthat's going to have to go out there.
(27:07):
And there's a lot of questions right nowon how they're going to do that.
We don't have that guidance, particularly for independent contractors;
as this amount flow through to a 1099 NEC,there's nowhere to put it.
On the form W-2,some places that it could go, but
ultimatelywe are looking at a lot of questions
on the actual practicalapplication of these.
(27:29):
One thing I just want to point outabout the OB3 is that it did not,
unlike the TCJA, it did not bring ina ton of new provisions.
A lot of it was just doing extensions
of TCJA provisionsthat were about to expire.
And so a couple examples of thosewere some fringe
(27:51):
benefits, movingexpenses, and bicycle commuting.
So there used to be an income exclusionfor those two amounts.
If you met certain requirementsthat the TCJA suspended,
OB3 came inand it made the suspension permanent.
So if you were hoping to get, you
know, moving expenseafter 2025, it's not going to be the case.
(28:12):
That is now permanent.
Now, on the flip side,still talking about fringe benefits.
It did do some good things.
So, for example, educational assistanceemployers have the ability to deduct up
to $5,250 of educational expensesfrom an employee's wages.
And a handful of years
ago, one of the things that was addedto the definition of a qualifying
(28:35):
educational expense was student loansand other items related to student debt.
And so, OB3 came in and it madethat provision, you know, permanent,
which was very nice, because now that'sgoing to continue to cover student debt.
It also added somethingregarding these new Trump accounts.
There is a $2,500 exclusion
(28:57):
that an employercan put into a Trump account for a child.
Obviously,there are some requirements here,
but that is also a new benefit.
It's not something that used to exist.
So there is an opportunitynow for employers to continue
to provide new fringe benefits with these Trump accounts.
Now, I will point out there's a questionthat you may have encountered
(29:18):
on whether that $2,500 is annualor is that a lifetime cap?
And the way it's written currently,
if you do an express reading of it,it looks like a lifetime cap.
But I think what we're going to see thatthis is actually an annual limitation.
So they're probably going to end up doinga technical correction for that amount.
Another thing that you're going to seeis they made some expansions
to the employer-providedchild care credit,
(29:41):
and the dependent care assistance program.
So there is more potential benefitunder both of those programs.
And they also expanded the paid familyand medical leave credit.
So there were some additional benefitsthat came as a result of those.
Now, last but certainly notleast is executive compensation
and it hit two areas.
(30:02):
To start, it hit section 162(m).
That's the $1 million deduction limitation
for public companies for renumerationpaid to what they call covered employees.
Now, thisis a topic that's fairly interesting
because it's been evolving over the years,especially with the TCJA
because the covered employeepre-TCJA was just
(30:23):
your CEO and your top threemost highly compensated officers.
CFOs were expressly excluded.
TCJA came inand it changed a lot of things.
It really expanded the scopeand coverage of this limitation.
One of the things that it hitthough, was covered employees.
So it added the CFO into that.
So now you had potentially five or you didhave five covered employees per year,
(30:48):
but another provision that it addedis once covered, always covered.
So if you were one of thosefive individuals,
one of those five covered employeesat any point, you would continue
to be a covered employee in perpetuityfor that company.
And then, again, the American Rescue Plan
Act made a pretty significant change.
(31:08):
It's going to start in 2027 by addingfive more covered employees.
So, now you have a floor of, at minimum,ten covered employees per year.
And what's even worse with this is,the old rules only apply to officers.
These new rules apply to all employees.
So what we're going to see hereis a scenario
(31:29):
where you have extremelyhighly compensated employees
that weren't officers and were never having the deduction on their wages
limited by 162(m).
All of a suddenthey're going to get pulled in.
We're talking, like, salesmen, peoplethat have really high earners
with big commissions, etc.
So now we've had another change
with the OB3 because they've expandedthe potential pool of
(31:52):
who can be considered a covered employeeby incorporating controlled group rule.
So this is much more expansive than the1504 affiliated rules that they did have.
So not only are more people nowgoing to start becoming covered employees,
we have a bigger pool of peoplethat we're going to have to consider.
And last but not least, on the topic of covered employees,
(32:13):
a very similar provision.
It's kind of a hybrid of 162(m),but it only applies to tax-exempt
entities is the section 4960 excise tax.
Now, that's a 21% taxthat is imposed on tax-exempt
orgs that, again, pay renumerationin excess of $1 million.
So there's a lot of similarities there.
(32:34):
And they also had a cap of fivecovered employees.
But that is now changed.
They've eliminated the cap entirely.
So we're not talking about a floor of ten.
There is no floor.
Anybody that has compensationover $1 million,
except for some expressly exceptedindividuals like medical professionals,
are going to be subject to this cap.
(32:55):
And so that's another huge limitation
that we're going to be seeingas there is no cap.
There potentially could be asignificant number of employees
of the largest tax-exempt entitiesthat are going to be subject to this 21%
excise tax because of their compensationover $1 million dollars.
So, there's a lot more.But I want to keep it at that.
I think those are probably the primary
(33:16):
provisions that are impacting compand ben out of the OB3.
There are a lot of questions,there's a lot of gray area.
There's a lot of stuffthat was not answered.
So we probably are going to startseeing technical corrections.
And other guidance is going to starthopefully clarifying a lot of these items
for us.
Dave, I think that wraps up our episode.
(33:37):
I just want to thank you againfor joining us.
Been very excited that you're hereat the firm, and I really look forward
to working with you.
Each episode will bring you what we calla Focused FORsight of the week,
an article or recordingthat might be of interest to you.
(33:59):
This week's Focused FORsight is an articlefrom our one and only Devin Tenney
called Compensation and BenefitsReconciliation Changes 101.
Lots of insightsthat build off of what you heard today.
You can always access our FORsightson the WNTO website
or the forvismazars.us websitemore broadly.
And that's our show.Thank you all for joining.
(34:20):
This was a really fun one.
Remember to subscribe and listen infor our next episode of the podcast.
Until next time.
The information set forth in this podcastcontains
the analysis and conclusionsof the panelists based upon his, her,
or their research and analysis of industryinformation and legal authorities.
Such analysis and conclusionsshould not be deemed
(34:43):
opinions or conclusions by Forvis Mazarsor the panelists
as to any individual situationas situations are fact-specific.
The listener should performtheir own analysis and form
their own conclusionsregarding any specific situation.
Further, the panelists’ conclusionsmay be revised without notice,
with or without changes in industryinformation and legal authorities.
On this episode, we'lllook into some of the biggest changes
in the world of compensation and benefits,including those from the OB three,
as well as some of those from the firstand second SECURE acts.
We welcome Dave Graf,a leader in the Private Client practice
here at Forvis Mazars who specializesin qualified retirement plans,
to join me to talk about this subject,which is very near and dear to my heart.
(00:22):
From your onestop for tax updates and analysis.
I'm Devin And I'm Iris.
It's Tuesday, August 19thand this is Tackling
Tax with Forvis Mazars.
(00:49):
Before we get startedwith our much-anticipated guest,
we always like to start our showwith what we call our Fast Four stories
that we thinkmight be most impactful to you.
So let's dive right into our FastFour stories of the week.
For our first
story of the day, we're going to tackletechnical correction.
(01:10):
So, a slew of technical correctionsto the OB three,
or OBBBA, could be expectedin the coming months.
Members of Congresshave returned to their states
and districts as Congress is on recessuntil September 2nd,
with many addressing concernsof their constituents about the act.
Senator James Lankford of the SenateFinance Committee was quoted saying,
(01:32):
whatever bill goes out, no matter how longor short it is, there will be something.
You'll go, oh,that was an unintended consequence of it.
Especially with the complexity of tax law.
So the number of scope of these technicalcorrections will largely be determined
once the JCT publishes its Blue Bookcovering the Act.
You know,I certainly look forward to the Blue Book.
(01:53):
I still have occasional nightmaresabout the Tax Cuts and Jobs
Act and assume that you've probablyhad a similar experience.
Iris. Oh, you know it.
It's a lot to dig through,but also some really good guidance there.
So this just likeTCJA was a major piece of tax legislation
so it's going to take years beforemost of the wrinkles are ironed out.
(02:16):
Absolutely.
For our second story
we're going to talk about the revolvingdoor at the IRS commissioner post.
So, the IRS is in search of its eighthIRS commissioner
for 2025,after President Trump removed Billy Long,
who only served in the positionfor less than two months.
Wait, sorry, did I hear eighth?
(02:39):
Is that right? The eighth commissioner?
Yeah, you certainly did.
And considering that this has historicallybeen a five-year appointment,
seeing this many commissioners in a singleyear is certainly out of the norm.
Now, moving forward, Scott Bessent, Secretary of the Treasury,
has stepped into the roleas acting commissioner
while he and others begina search for the eighth
(03:01):
and hopefully finalIRS Commissioner of 2025.
Now, Long was not the onlynotable departure; as the head
of the Department of Justice Tax Division,Karen Kelly has also stepped down.
Now, this really shouldn'tcome as too much of a surprise
because last monthit was announced by DOJ officials
that they have a planto eliminate the tax division
(03:24):
and relocate its attorneysto other divisions within the department.
So, it's not necessarily a big surprise.
And I also don't necessarily anticipatesomeone filling that role.
Well, our show is Tackling Tax,but here we also tackle tariffs.
So, another week,another update on tariffs.
To start,the US and China have agreed to pause
tariff hikes on each otherfor an additional 90 days,
(03:47):
halting a significant tariff increaseby both sides.
Reciprocal tariffshave also gone into effect on dozens
of countries, with ratesranging from 10 to 41%.
Additionally,the de minimis exception will end
for all countries effective August 29th.
Iris,if you don't mind if I interject quickly.
The de minimis exception,can you maybe provide some context
(04:09):
on what that is and what this means?
Sure, historically, importedgoods valued at or under that $800 mark
have fallen under a de minimis exceptionfrom customs clearance and duties.
So, up until now, the exceptionhas been in place for global imports,
with the exception of those from China,which was lifted earlier in May.
(04:29):
So, however, starting August 29th,all imports, regardless of their value,
will be required to go through customsclearance and face duty rates.
Last but not least,let's talk about the new provisions,
no tax on tips and overtime.
So, the IRS recently announcedthat there's not going to be any changes
in 2025 to withholding tables or tocertain information returns for that year.
(04:53):
They primarily stated that they're
not going to be making these changesbecause they want to avoid disruptions
to tax filing
and also give the IRS enough timeto implement these changes effectively.
I mean, with the Billy Long news,I understand why
they probably want that additional time.
So, this announcement also saidthat they are working
on guidance for 2026.
And that's going to include,you know, new withholding tables
(05:17):
and also how employers should report tipsand overtime to their employees.
So, the IRS is going to coordinatewith employers, payroll
providers and tax professionals to helpkind of ensure a smooth transition here.
On another front,
Democratic lawmakers from Nevadahave shared a letter with the Treasury
and IRS, urging themto support a number of changes
(05:37):
to these laws onno tax on tips and overtime.
Basically asking for a lot of things but
they include auto gratuitiesas qualified tips,
which are currently excludedunder the provision.
What is an auto gratuity?
I mean, I think that probably could bea lot of things, right?
Yeah.
So the new law requiresthat tips be qualified
(06:00):
tips for this purpose of the deduction.
They have to be voluntary.
So, if we have somethinglike a service fee or automatic gratuity
where there's like a set percentagethat’s automatically charged
to your bill, typicallywhen you have parties of a certain size,
that's not considered voluntaryin this case.
And so,those service charges are not, and auto
(06:23):
gratuities are not,going to be deductible as a qualified tip.
Now the Nevada lawmakershave also put a request in
to make the provision permanent,as it currently is set to expire in 2028.
They've also asked to have
a more broad definition of occupations
that are applicable to claim this,the tips deduction.
(06:46):
And additionally,and I found this one important,
they've also asked for joint filersto be able to claim $25,000 each.
Currently, it's capped at $25,000
in total, regardlessif you're a single filer or joint filer.
So, kind of like we have with overtime,where you have $12,500 per person,
up to $25K when you're filing joint,they want to see that here.
(07:08):
So the cap would actuallybe $50K for joint filers.
This segment we call Planning Insightswhere we examine
current events in the tax worldand some of the resulting strategies.
Today's insight, as I had mentionedearlier, is going to be on a topic near
(07:29):
and dear to my heart,and that's because it's my primary area
of specialty, Comp and Ben.
And that's particularly in the moreonerous rules that govern executive comp
and non-qualified deferred comp,like 409A and 280G
and a bevy of other areas that fallunder that Comp and Ben umbrella.
Now, one area that I rarely touchis that of qualified plans.
(07:51):
But fortunately, the firmhas a very strong practice in this area,
which grew even stronger recently
with the addition of our guestfor today's episode, Dave Graf.
Dave, welcome to Tackling Tax.
Devin, thank you very much.
It's an honor to be here with you guysand look forward to talking qualified
plans, the Internal Revenue Code, ERISA,
(08:14):
all those things that employee
benefit nerds like myselfenjoy talking about.
Yeah, I think you pretty much
have to be a nerd to work in this area,even more so than tax in general.
But, you know, Dave, we work at ForvisMazars, a public accounting firm, but
you have a very nontraditional backgroundand pathway into public accounting.
(08:35):
So I'm wondering,can you maybe give us a little bit
of an introduction about yourself?
You know, how did you kind of grow upin this area, and end up at the firm?
And what are you really doing hereat Forvis Mazars?
Sure. Devin, I'm happy to do so.
And it's kind of funny how,you know, the circle of life works.
Once upon a time, I was
(08:58):
actually working at a big eight
accounting firm in Coopers and Lybrandand going to law school at night
and working my way throughand got finished.
And then the decision was either
stay with Coopersor go out and work at a law firm.
(09:19):
And it was really a tough decision
but I went ahead and chose the path of going to a law firm.
And that's what I've donenow for the last, 40 years, give or take.
And, you know, I got towards
the end of my career,with the law firm that I was
(09:39):
with for over 30 yearshere in Little Rock, Arkansas, and,
you know, I just missed peoplethat kind of had my same values.
And at the top of that list is basically,
you know, the concept of integrityalways trumps economics.
And so,I remember here, 10-15 years ago,
(10:05):
met a gentleman by the name of ChrisDoolittle here in our Little Rock office.
And we got to know one anotherthrough one of his family’s
retirement plansthat had all sorts of trouble with
the IRS, the Department of Labor,
and then we'll throw in the PensionBenefit Guaranty Corporation as well.
(10:27):
All three of those governmental agencies,
and was able to pull his family's plan
out of the ditch and retain the taxqualified status and whatnot.
And so,I reached out to Chris and said, hey,
you know, I'm at the stage in my careerwhere I'd really like to end it
(10:47):
on a good note, and I'd like to do sowith a bunch of guys that are like you.
In other words,a bunch of Chris Doolittle's. And so,
you know,
we talked and talkedand talked some more and the process was,
you know, multiple months, but,
at the end of the day was offeredthe opportunity
(11:10):
to work with the retirement planconsulting group.
And people asked me, Dave,how do you like it over there?
Basically, even though
I'm not technically practicinglaw anymore, I continue to
consult on all sortsof qualified retirement plan issues,
(11:31):
including the preparation of documents
which we just got approved to go to the FTWilliam document package,
which is going to be a real improvementfor us
as far as how we can offer our plansto clients.
But, people askme, well, hey, how's that, what's it
(11:54):
like being essentially a consultantas opposed to an attorney? And
I'm just really blessed,
Devin.
I mean, the way I characterizeit is: within our group of 12,
it's 12 CPAs and one lawyer, as in me.
But, I'm with an all-star group
(12:16):
of professionals that are Hall-of-Famersas human beings.
And so just, tremendously blessed to be a part
of Forvis Mazars and
this is where I'm going to wrap upmy career here, with the team here.
Now, so, you work in retirementplanning on the qualified side.
And that may be the most active areain terms of like, new legislation
(12:41):
and changes and really kind of what'sevolving in the world of Comp and Ben.
So, I was, you know,wanting to talk a little bit about what
you're really seeing specificallywith the SECURE and SECURE 2.0 Acts
and kind of touching on this themeof Roth-ification, you know, what is that?
You know,and also what motivated Congress, to,
(13:03):
you know, put these two huge actsinto place in the first place?
Yeah.
Great question, Devin.
When I first started,
in the area of employee benefits,
and I'm not going to admit how long agothat was because it's been a while.
But, you know, the focus was more
so on, defined benefit pension plansthat companies were there
(13:28):
to kind of guide you through the path of your career.
And then, in additionto giving you a gold watch,
would provide you with a pensionslash annuity for the rest of your life.
And the problem with pension plans,
generally speaking, is that oftentimes,
(13:50):
they're not completely funded for various reasons.
And so you wind up, actually,that type of plan
becoming a money pit on the employer side.
And so
over time,the focus was to, hey, let's shift
this responsibility for retirement.
(14:12):
More so from the employer's responsibilityto the employees.
And so, that was where the adventof the 401(k) plan came in.
And these most recent piecesof legislation,
those are geared towards
adding on to making it moreso
(14:35):
the employee's responsibilityto save for their retirement.
So you've got all sorts of provisionshere.
With the intent to have the employee
shoulder this burdenas opposed to the employer.
And I guess one good thing for me, Devin,
being in the employee-qualified plan worldis that, you know,
(15:00):
I kind of refer to,the SECURE Act and the SECURE 2.0 Act,
as the full employment act for employeebenefit professionals like myself.
Because there's getting ready to be a ton,and I mean a ton, of work
coming up over the next couple of yearsin terms of amendments and restatements,
(15:23):
good-faith amendments, decisions
as to are we going to add a Roth featureso that your highly paid
individuals who make $145,000or more can do catch-up contributions?
I mean, there's
just a ton of
different benefit changescoming down the pike.
(15:45):
Would you say that a lot of these changeswere beneficial
for retirement saving, planning?
You know, as far as I'm aware,if I recall correctly, the SECURE stands
for Setting Every Community Upfor Retirement Enhancement,
and that, this was,kind of, designed to encourage
both employersand employees to participate.
(16:05):
Is that what you've seenbased on the provisions that came out
with the 1.0 and then SECURE 2.0?
Has it really been a good motivation?
Has it added too much complexity?
And, you saidthere's some big stuff coming.
If you, you know, had to sharejust a couple
huge insights that our listenersprobably should be aware
of that are upcoming;what would you want to share?
(16:27):
Yeah, that's a very good question, Devin.
It's kind of funnythat both of these acts,
kind of behind the scenes, the intent wasto, quote unquote, “simplify” things.
And,
I think they kind of whiffed on that.
I mean, the SECURE 2.0
(16:49):
Act has over 93 different
qualified plan changes in there.
And, frankly,a lot of them are pro-employee,
if you would, in terms of various types
of distribution options,which include, like,
a small distributionamount for emergency situations.
(17:13):
There's domestic abuse situations.
Just a lot of little small distributionfeatures.
There's a qualified birthor adoption feature
where, if an individual is about to havea new addition to the family,
that they could pull out up to $5,000from their retirement account
(17:36):
and use that to pay birthor adoption expenses.
And it also gives them the opportunity,
if they so choose, to repay that moneyback to the plan.
So, it would never be taxable.
But, you know, honestly, yeah.
You're not going to see many employersadd any of those features.
(17:58):
But what you are going to seeare a couple features that
are going to surprise people.
And probably at the top of the list
is this whole to-do about long-termpart-time employees.
And, prior to the SECURE Act,
(18:19):
and I've got several hospitalswhere we've got a number of employees
that they don't work1,000 hours in the 12-month period.
And we honestly at the employer-level
like that because we didn'thave to bring them into the 401(k) plan
or make employer matching
(18:41):
contributions or profit-sharingcontributions, for that matter.
But, what the SECURE Act said was that,
hey, if you're a long-term part-time
employee,and back in 2000, under the SECURE Act,
if you had three years of where you had500 or more hours of service,
(19:02):
the employer had to letyou come into the plan
and start making 401(k) contributions.
Now, they were not requiredto make employer
matching or profit-sharing contributions,but they had to let these people
come into the plan for 401(k) purposes.
And then the SECURE 2.0Act expanded on that
(19:26):
and said, hey, you know, it'sno longer going to be three years.
If you've had two years of 500or more hours of service,
you've got to come in for 401(k) purposes.
And that new ruletakes effect in 2025. So,
you know, you're going to have
some people surprised by that.
(19:49):
Another rule that,
frankly,is going to catch a lot of new plans
by surprise is that
and this, again,is effective as of 1/1/2025,
if you have a new plan and an employer
that has more than 10 employees,
(20:11):
they have to automatically enroll
all of their employeesin this new 401(k) plan.
There's no ability to let them decidewhether they want to come in or not.
And with these automatic enrollmentfeatures,
employers are going to have to,
(20:31):
at a minimum, start withholding 3% of pay.
And that goes up each year by a percent
and ultimately could get as highas 15% of pay.
So, you're going to have a lotof additional administration
in terms of, because there'sgoing to be employers that
(20:52):
a lot of
these employeesare not going to want to participate,
but they're going to have to proactivelygo out there and get some sort of piece
of paper back, saying that they don'twant to participate in the plan.
And then of the trifecta,
if you would, of surprisetype changes is one coming
(21:14):
up, Devin, in 2026 and
this is a really convoluted provision,but it's one that was thrown into this
SECURE 2.0 Act, frankly, to generate
some tax revenue and keep people happy.
But it has to do with this Roth-ification,
(21:36):
if you would, of catch-up contributions.
And what the law saysis that any employee, it's
not a highly compensated employee,it's a highly
paid individual, i.e., an HPI
as opposed to an HCI or HCE, I'm sorry.
(21:59):
Well, and what it says is that,
if you want to do catch-up contributions
and just to back up for everybodyon the podcast.
Anyone who's 50 or above
can elect to, in addition to their 402(g)limit of 401(k) contributions,
(22:20):
which is $23,500 here in 2025,
you can do an additional $7,500
if you're 50 or aboveas a catch-up contribution.
And if you're actually between the ages of60 to 63,
you can do an additional
$3,750.
(22:41):
It's called the super catch-up.
And that's $11,250if you fall within any of those years.
But beginning 1/1/2026,
if you make more than $145,000,
your catch-up contributions,you can still do them
but they have to be in the formof a Roth after tax contribution.
(23:05):
So, there are a number of plans out thereright now that do not offer Roth.
And so, if they're going to want to keep
their higher paid people happy.
And again, it starts at $145,000,
not $160,000, which is the quote
unquote “highly compensated employee”threshold.
(23:30):
These contributions will have to be on a Roth after-tax basis.
So, we're getting ready to have a lotof fun here going into the fourth quarter,
because there's going to be a lot of plansthat,
in order to continuewith catch-up contributions
that do not have a Roth provision,they will have to be amended
(23:50):
before January 1st, 2026, to
offer this catch-up feature to theirhigher paid individuals.
And, you know, I've had a lot of questionscome up on this about,
well, okay, we're going to do thisRoth feature.
We're just going to have it apply to these people
(24:11):
that make $145K or more.
And that's a big
absolute no.
If you're going to bring the Roth featurein, it has to be offered
to everybody to avoid any type of nondiscrimination issues.
Well Dave,I'd say that's all incredibly insightful,
(24:32):
but certain people may havea different definition of fun than you.
Yeah, I hear you.
That may be why you work in this area.
Well, Devin, as I mentioned,there were 93 changes
in the SECURE 2.0 Act,and we covered maybe three of them.
So there's 90 left.
But let's go on to some exciting thingsthat are happening in your world,
(24:56):
in particularwith respect to the OB3 legislation.
Yeah, absolutely.
And, you know, therecertainly were not 93 changes in OB3,
but there were a fair amountthat I think are worth discussing.
And, you know,I talked earlier on this episode
about the no tax on tipsand no tax on overtime provisions.
(25:17):
You know,
they were a campaign promise from Trumpthat ultimately did make it into the act.
And they both provide for above-the-linedeductions for individuals
that make certain amounts.
Now there are limits onwho actually can take this deduction
and the amounts that can be taken,
as well as the source of those funds.
(25:39):
If you're going to have tips, for example,
those tips must be limitedto, like, voluntary amounts.
Qualified overtime, on the other hand,is going to be based
on a definitionof the Fair Labor Standards Act.
And so, it's also limited onlyto an actual specific amount of overtime.
(25:59):
And not all overtime wages, but only theadditional amount over their regular pay.
Some things to really know aboutthese provisions that I think stand out
is there's a phase out.
So if you make over $150K or $300K joint,you are going to be phased out.
It's going to be $100per thousand dollars over that limit.
And these deductions are only availablethrough 2028.
(26:22):
Now, again, this is an employee deductionon their tax return.
This is not an income exclusion.
So employers are going to have to reportthese amounts on forms
W-2 and still do all the applicablewithholding, at least in ‘25.
That may change next yearwhen we get these new withholding tables.
But for now, they're still going to haveto report all of these amounts.
(26:46):
And there's going to be additionalreporting from employers.
The problem iswe just don't have any guidance.
So, the employer is going to have to state the occupation
that they're in to ensurethat it's a qualifying occupation.
They're going to have to identify
and provide the actual amount of qualifiedtips or qualified overtime.
There's additional informationthat's going to have to go out there.
(27:07):
And there's a lot of questions right nowon how they're going to do that.
We don't have that guidance, particularly for independent contractors;
as this amount flow through to a 1099 NEC,there's nowhere to put it.
On the form W-2,some places that it could go, but
ultimatelywe are looking at a lot of questions
on the actual practicalapplication of these.
(27:29):
One thing I just want to point outabout the OB3 is that it did not,
unlike the TCJA, it did not bring ina ton of new provisions.
A lot of it was just doing extensions
of TCJA provisionsthat were about to expire.
And so a couple examples of thosewere some fringe
(27:51):
benefits, movingexpenses, and bicycle commuting.
So there used to be an income exclusionfor those two amounts.
If you met certain requirementsthat the TCJA suspended,
OB3 came inand it made the suspension permanent.
So if you were hoping to get, you
know, moving expenseafter 2025, it's not going to be the case.
(28:12):
That is now permanent.
Now, on the flip side,still talking about fringe benefits.
It did do some good things.
So, for example, educational assistanceemployers have the ability to deduct up
to $5,250 of educational expensesfrom an employee's wages.
And a handful of years
ago, one of the things that was addedto the definition of a qualifying
(28:35):
educational expense was student loansand other items related to student debt.
And so, OB3 came in and it madethat provision, you know, permanent,
which was very nice, because now that'sgoing to continue to cover student debt.
It also added somethingregarding these new Trump accounts.
There is a $2,500 exclusion
(28:57):
that an employercan put into a Trump account for a child.
Obviously,there are some requirements here,
but that is also a new benefit.
It's not something that used to exist.
So there is an opportunitynow for employers to continue
to provide new fringe benefits with these Trump accounts.
Now, I will point out there's a questionthat you may have encountered
(29:18):
on whether that $2,500 is annualor is that a lifetime cap?
And the way it's written currently,
if you do an express reading of it,it looks like a lifetime cap.
But I think what we're going to see thatthis is actually an annual limitation.
So they're probably going to end up doinga technical correction for that amount.
Another thing that you're going to seeis they made some expansions
to the employer-providedchild care credit,
(29:41):
and the dependent care assistance program.
So there is more potential benefitunder both of those programs.
And they also expanded the paid familyand medical leave credit.
So there were some additional benefitsthat came as a result of those.
Now, last but certainly notleast is executive compensation
and it hit two areas.
(30:02):
To start, it hit section 162(m).
That's the $1 million deduction limitation
for public companies for renumerationpaid to what they call covered employees.
Now, thisis a topic that's fairly interesting
because it's been evolving over the years,especially with the TCJA
because the covered employeepre-TCJA was just
(30:23):
your CEO and your top threemost highly compensated officers.
CFOs were expressly excluded.
TCJA came inand it changed a lot of things.
It really expanded the scopeand coverage of this limitation.
One of the things that it hitthough, was covered employees.
So it added the CFO into that.
So now you had potentially five or you didhave five covered employees per year,
(30:48):
but another provision that it addedis once covered, always covered.
So if you were one of thosefive individuals,
one of those five covered employeesat any point, you would continue
to be a covered employee in perpetuityfor that company.
And then, again, the American Rescue Plan
Act made a pretty significant change.
(31:08):
It's going to start in 2027 by addingfive more covered employees.
So, now you have a floor of, at minimum,ten covered employees per year.
And what's even worse with this is,the old rules only apply to officers.
These new rules apply to all employees.
So what we're going to see hereis a scenario
(31:29):
where you have extremelyhighly compensated employees
that weren't officers and were never having the deduction on their wages
limited by 162(m).
All of a suddenthey're going to get pulled in.
We're talking, like, salesmen, peoplethat have really high earners
with big commissions, etc.
So now we've had another change
with the OB3 because they've expandedthe potential pool of
(31:52):
who can be considered a covered employeeby incorporating controlled group rule.
So this is much more expansive than the1504 affiliated rules that they did have.
So not only are more people nowgoing to start becoming covered employees,
we have a bigger pool of peoplethat we're going to have to consider.
And last but not least, on the topic of covered employees,
(32:13):
a very similar provision.
It's kind of a hybrid of 162(m),but it only applies to tax-exempt
entities is the section 4960 excise tax.
Now, that's a 21% taxthat is imposed on tax-exempt
orgs that, again, pay renumerationin excess of $1 million.
So there's a lot of similarities there.
(32:34):
And they also had a cap of fivecovered employees.
But that is now changed.
They've eliminated the cap entirely.
So we're not talking about a floor of ten.
There is no floor.
Anybody that has compensationover $1 million,
except for some expressly exceptedindividuals like medical professionals,
are going to be subject to this cap.
(32:55):
And so that's another huge limitation
that we're going to be seeingas there is no cap.
There potentially could be asignificant number of employees
of the largest tax-exempt entitiesthat are going to be subject to this 21%
excise tax because of their compensationover $1 million dollars.
So, there's a lot more.But I want to keep it at that.
I think those are probably the primary
(33:16):
provisions that are impacting compand ben out of the OB3.
There are a lot of questions,there's a lot of gray area.
There's a lot of stuffthat was not answered.
So we probably are going to startseeing technical corrections.
And other guidance is going to starthopefully clarifying a lot of these items
for us.
Dave, I think that wraps up our episode.
(33:37):
I just want to thank you againfor joining us.
Been very excited that you're hereat the firm, and I really look forward
to working with you.
Each episode will bring you what we calla Focused FORsight of the week,
an article or recordingthat might be of interest to you.
(33:59):
This week's Focused FORsight is an articlefrom our one and only Devin Tenney
called Compensation and BenefitsReconciliation Changes 101.
Lots of insightsthat build off of what you heard today.
You can always access our FORsightson the WNTO website
or the forvismazars.us websitemore broadly.
And that's our show.Thank you all for joining.
(34:20):
This was a really fun one.
Remember to subscribe and listen infor our next episode of the podcast.
Until next time.
The information set forth in this podcastcontains
the analysis and conclusionsof the panelists based upon his, her,
or their research and analysis of industryinformation and legal authorities.
Such analysis and conclusionsshould not be deemed
(34:43):
opinions or conclusions by Forvis Mazarsor the panelists
as to any individual situationas situations are fact-specific.
The listener should performtheir own analysis and form
their own conclusionsregarding any specific situation.
Further, the panelists’ conclusionsmay be revised without notice,
with or without changes in industryinformation and legal authorities.
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