(October 22, 2024) On October 21, 2024, the IRS released final regulations on income tax withholding for IRA and other retirement plan distributions. Specifically, these regulations add to existing rules and address distributions that are made to recipients who live outside the United States or who do not provide their U.S. residence address. Proposed regulations on this subject were published in 2019, but no comments were received by the IRS and no public hearing was requested or held. So the final regulations are now adopted in substantially the same form as the proposed regulations.

The final withholding regulations address four main situations.

1. Recipients with a military or diplomatic post office address. Because of the minimal likelihood of tax avoidance, the IRS will treat military and diplomatic personnel (and their families) who have distributions delivered to military or diplomatic post office addresses (e.g., APO, or Army Post Office) as being located within the United States.
2. Recipients with a residence address located within the U.S. Generally, those who provide a valid U.S. residence address may elect no withholding. If, however, the recipient instructs the payor (e.g., the financial organization) to send the distribution outside the U.S., the election not to withhold is no longer valid.
3. Recipients with a residence address located outside the U.S. or who have not provided a residence address. Generally, these recipients cannot waive tax withholding on IRA distributions. This is true even if the recipient requests that the funds be deposited with a financial organization located within the U.S.
4. Recipients to which a 30% withholding rate (or a treaty rate) applies. Nonresident aliens are typically subject to the 30% withholding rate unless they elect the applicable treaty rate (e.g., by completing Form W-8BEN).

These final regulations apply to distributions made on or after January 1, 2026, but taxpayers and payors may apply them to distributions as of October 21, 2024

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(February 6, 2018) In News Release IR-2018-19, the IRS announced today that the Tax Cuts…

IRS Expected to Post Hurricane-Related Taxpayer Forms/Publications Soon

(February 5, 2018) The IRS is expected to post final versions of the following taxpayer…

2017 IRA/HSA Contribution Deadline

(January 31, 2018) The deadline for making Traditional and Roth IRA contributions as well as…

IRS Confirms 2017 Conversions May Be Recharacterized

(January 18, 2018) The IRS has updated the IRA FAQs-Recharacterization of IRA Contributions on its website to…

Back-Door Roth IRA Contributions Endorsed by Congress

(January 12, 2018) A back-door Roth IRA contribution whereby an individual who is not eligible…

Effective Date of Recharacterization Repeal Clarified

(December 29,2017) There has been confusion surrounding the effective date of the provision in the…

House and Senate Pass Tax Reform Bill; Awaiting President Trumps Signature

(Updated December 22, 2017) President Trump signed the Tax Cuts & Jobs Act into law…

DOL Delays Key Investment Fiduciary Requirements to Mid-2019

(November 29, 2017) As anticipated, the Department of Labor (DOL) has recently announced a further…

2018 COLAs Issued

(October 19, 2017) On October 19, 2017, the IRS issued Notice 2017-64 to announce the…

President Signs Bill Providing Access to Retirement Plan Savings for Hurricane Victims

(October 2, 2017) On September 29, 2017, President Trump signed into law the Disaster Tax Relief…

House & Senate Pass Special Retirement Plan Legislation for Hurricane Victims

(September 29, 2017) On September 28, 2017, the House of Representatives and Senate both passed…

Relief Granted for More Hurricane Victims of Hurricanes

(September 19, 2017) The IRS has issued several pronouncements which provide retirement plan (including IRA)…

DOL Guidance for Hurricane Irma Victims

(September 18, 2017) The Department of Labor (DOL) has issued News Release 17-1297-NAT which provides guidance or…

IRS Posts UPDATED IRA Documents

(September 16, 2017) On September 16, 2017, the IRS posted updated model IRA document language…

IRS Liberalizes Access to Plan Loans & Hardship Distributions for Hurricane Irma Victims

(September 13, 2017) The IRS has issued Announcement 2017-13 that provides potential retirement-plan specific relief to Hurricane…

DOL Posts FAQs for Participants and Beneficiaries Following Hurricane Harvey

(September 5, 2017) The Department of Labor (DOL) has released a set of Frequently Asked…

DOL Guidance for Hurricane Harvey Victims

(September 5, 2017) The Department of Labor (DOL) has issued News Release 17-216-NAT which provides guidance for…

Retirement Plan Relief for Victims of Hurricane Harvey

(September 5, 2017) The IRS has issued several pronouncements which provide relief to victims of…

Treasury Announces Steps to Wind Down myRA Program

(July 28, 2017) ​Washington, D.C. – The U.S. Department of the Treasury today announced that…

2018 HSA COLAs Issued

(May 4, 2017) The IRS issued Revenue Procedure 2017-37 to announce the 2018 cost-of-living adjustments…

DOL Announces 60-Day Delay to Fiduciary Rule Effective Date

(April 5, 2017) On Tuesday, April 4, 2016, the Department of Labor (DOL) released information…

DOL Proposes 60-Day Delay for Fiduciary Rule

(March 1, 2017) The Department of Labor (DOL) today released a notice of proposed rulemaking…

2017 Instructions for Forms 1099-R and 5498 Posted

(December 13, 2016) The IRS has posted the final version of the 2017 Instructions for…

2016 IRA/HSA Contribution Deadline

(December 7, 2016) The deadline for making Traditional and Roth IRA contributions as well as…

Department of Labor Issues FAQ Concerning Fiduciary (aka "conflict-of-interest") Regulations

(October 27, 2016) Today, the Department of Labor (DOL) released the first in a series…

2017 COLAs Issued

(October 27, 2016) The IRS issued Notice 2016-62 today to announce the 2017 cost-of-living adjustments…

IRS Provides Loan/Distribution Flexibility for Victims of Louisiana Storms

(August 30, 2016) In Announcement 2016-30, the IRS outlines specific relief that is potentially available…

DOL Publishes Final Rule on State-Sponsored IRAs

(August 25, 2016) Today the United States Department of Labor (DOL) published final rules that…

Wavier of 60-Day Rollover Requirement, Effective Immediately

(August 24, 2016) Earlier today, the IRS published important new guidance concerning rollover relief for…

2017 HSA COLAs Issued

(May 2, 2016) The IRS issued Revenue Procedure 2016-28 to announce the 2017 cost-of-living adjustments…

Final Fiduciary Regulations Signal Industry-Wide Changes

(April, 6, 2016) On Wednesday, April 6, 2016, the Department of Labor (DOL) released the…

IRA Bankruptcy Exempt Amount Increases

(March 14, 2016) When the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA)…

President Obama Outlines Retirement Savings Changes

(January 28, 2016) The White House has released a fact sheet that identifies several proposals…

Alert: Legislative Changes Enacted

On Friday, December 18, 2015, Congress presented, and President Obama signed into law, the “Consolidated…

QCD Permanency Legislation Pending

(December 16, 2015) Late last night, the House Ways and Means committee came to an…

DOL Releases Guidance on State-Sponsored IRAs

(November 16, 2015) The United States Department of Labor (DOL) published a significant package of…

myRA® Program Expands by Adding New Funding Methods

(November 5, 2015) On November 4, 2015, the Treasury Department has announced that the myRA®…

Proposed Regulations Published Regarding Treatment of Same-Sex Marriage for Federal Tax Purposes

(October 23, 2015) The U.S. Department of the Treasury and the Internal Revenue Service (IRS)…

2016 COLAs Issued

On October 21, 2015, the IRS issued News Release IR 2015-118 to announce the 2016…

2016 HSA COLAs Issued

(May 5, 2015) The IRS issued Revenue Procedure 2015-30 to announce the 2016 cost-of-living adjustments…

DOL Issues New Fiduciary Regulations

On Tuesday, April 14, 2015, the Department of Labor (DOL) published a sweeping package of…

QCDs Extended for 2014

(December 22, 2014) President Obama signed the Tax Increase Prevention Act of 2014 into law…

Transition Rule Announced for IRA Rollovers

(November 10, 2014) The IRS released News Release IR-2014-107 and Announcement 2014-32 as follow-up to…

2015 COLAs Issued

On October 23, 2014, the IRS issued News Release IR 2014-99 to announce the 2015…

Long-Awaited IRS Guidance Clarifies Rollover Options for After-Tax Savings

(September 18, 2014) The IRS has released long-awaited guidance in the form of Notice 2014-54…

House Passes QCD Permanency Bill

(July 17, 2014) On July 17, 2014, the House of Representatives passed the America Gives…

IRS Withdraws Proposed Regulation on 12- Month Rollover Rule

(July 11, 2014) As part of its ongoing initiative to change its enforcement policy with…

QLAC Final Regulations Impact RMD Calculations

(July 2, 2014) On July 2nd the Treasury released final regulations relating to the use…

IRS Provides Clarification to New Rollover Rule

(June 19, 2014) Convergent has recently learned from IRS officials that the IRSs position outlined…

Inherited IRAs Not Protected From Bankruptcy

(June 12, 2014) On June 12, 2014, the United States Supreme Court ruled unanimously that…

2015 HSA COLAs Issued

(April 23, 2014) The IRS issued Revenue Procedure 2014-30 to announce the 2015 cost-of-living adjustments…

SSA Letter Forwarding Program Discontinued

(April 17, 2014) The Social Security Administration has announced that the Social Security Administration will…

IRS Notice Provides Guidance on Application of Windsor Decision

(April 4, 2014) The IRS has released Notice 2014-19 which provides guidance on the prospective…

Guidance Issued to Promote Rollovers to Employer Plans

(April 3, 2014) The U.S. Department of Treasury and the IRS has issued Revenue Procedure…

New Rollover Rule Applies Separately to Roth

(March 27, 2014) Included in the March 27, 2014, edition of the IRSs Employee Plan…

IRS Changes Rollover Rule

(March 20, 2014) The IRS released Announcement 2014-15 today announcing that the agency intends to…

MyRA Information Posted

The Treasury Department has posted information on its TreasuryDirect website regarding the myRA (my Retirement…

Tax Court Ruling Conflicts with 12-Month Rollover Rule

A recent decision from the United States Tax Court regarding the 12-month rollover rule is…

Obama Announces Retirement Initiatives

As part of the 2014 State of the Union address, President Barack Obama pledged to…

2014 COLAs Issued

On October 31, 2013, the IRS issued News Release IR 2013-86 to announce the 2014…

2014 COLAs Likely to Be Released October 30th

The Bureau of Labor Statistics has announced it has scheduled the release of the September…

DOL's EBSA Follows IRS with Guidance Recognizing Same-Sex Marriages

On September 18, 2013, the U.S. Department of Labor's (DOL's) Employer Benefits Security Administration (EBSA)…

Same-Sex Marriages Will Be Recognized for Federal Tax Purposes

On August, 29, 2013, the Department of the Treasury and the Internal Revenue Service (IRS)…

Plan Investment Disclosure Timing May Be Reset

The U.S. Department of Labor's Employee Benefits Security Administration released Field Assistance Bulletin (FAB) 2013-02…

Supreme Court Case Likely to Effect Employer Sponsored Retirement Plans and IRAs

On Wednesday, June 26, 2013, the United States Supreme Court ruled on theUnited States v.…

Proposed Legislation Could Stall Issuance of Fiduciary Regulations

On June 19, 2013, the House Financial Services Committee passed the Retail Investor Protection Act…

IRA Bankruptcy Exemption Amount Increases

When the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA) was enacted the…

2014 HSA COLAs Issued

On May 2, 2013, the IRS issued Revenue Procedure 2013-25 to announce the 2014 cost-of-living…

Update: IRS Comments on "Carryback 2012 QCDs

As part of the American Taxpayer Relief Act of 2012 (ARTA), the IRA option for…

American Taxpayer Relief Act of 2012 Contains Retirement Plan Related Provisions

H.R. 8, the American Taxpayer Relief Act of 2012 (ATRA) has been passed by both…

DOL Issues Retirement Plan Guidance for Hurricane Sandy Victims

On November 20, 2012, the Department of Labor's Employee Benefits Security Administration issued a news…

IRS Relaxes Loan and Hardship Withdrawal Rules for Hurricane Sandy Victims

On November 16, 2012, the IRS released Announcement 2012-44 providing potential relief to Hurricane Sandy…

Tax Relief for Victims of Hurricane Sandy and Hurricane Isaac

The IRS has issued numerous news releases which grant tax relief for victims of Hurricanes…

2013 COLAs Issued

On October 18, 2012, the IRS issued News Release IR 2012-77 to announce the 2013…

IRS Letter Forwarding Program Discontinued

In Revenue Procedure 2012-35, the IRS announced that the IRS's letter forwarding program is no…

Senate Passed ESA Bill Now With House

A modified version of the Middle Class Tax Cut Act (S. 3412), which was recently…

Senate Tax Bills Include Extension of ESA Sunset Provisions

Senators on both sides of the aisle have recently introduced tax bills that include a…

IRS to Increase Focus on Retirement Plan Compliance

As a direct result of the Madoff scandal, the IRS has focused considerable compliance efforts…

IRS to Develop Strategy to Target Noncompliance with IRAs

According to several reports released in recent years by the Treasury Inspector General for Tax…

DOL Issues FAQs on Fee Disclosure Rules

The U.S. Department of Labors Employee Benefits Security Administration (EBSA) has issued guidance intended to…

Roth Regulations for TSP Issued

On May 7, 2012, the Federal Retirement Thrift Investment Board issued final regulations pertaining to…

2013 HSA COLAs Issued

On April 27, 2012, the IRS issued Revenue Procedure 2012-26 to announce the 2013 cost-of-living…

Financial Advisor Magazine Article Spotlights 2012 Roth Conversion Opportunity

Mr. Ben Norquist, Founder and President of Convergent Retirement Plan Solutions, was recently interviewed for…

Additional Reporting Codes for 2012 Released

The IRS has posted the 2012 Form 5498. Included in the updated participant instructions are…

Traditional IRAs May Now Receive Airline Payments Rollovers

The FAA Modernization and Reform Act of 2012 that was signed into law on February…

IRA-Related Provisions in President's Budget Proposal

On February 13, 2012, President Obama released his budget proposal for fiscal year 2013. While…

Proposed Guidance Package on Lifetime Income

Over time the use of annuities and other lifetime income in retirement plans has been…

Final Service Provider Fee Disclosure Regulations Issued

On February 2, 2012, the Department of Labors Employee Benefits Security Administration (EBSA) issued final…

2011 IRA Contribution Deadline - April 17, 2012

The deadline for making Traditional and Roth IRA contributions for tax year 2011 is Tuesday,…

2012 COLAs Issued

On October 20, 2011, the IRS issued News Release IR 2011-103 to announce the 2012…

DOL to Re-propose Fiduciary Rule

The Department of Labor has announced that it will re-propose its rule on the definition…

DOL Issues Interim Electronic Disclosure Policy

The U.S. Department of Labors (DOL) Employee Benefits Security Administration EBSA issued Technical Release 2011-03…

Tax Relief for Victims of Hurricane Irene (And Other Disaster Situations)

The IRS has issued numerous news releases which grant tax relief for victims of Hurricane…

DOL's EBSA Issues Final Rule to Extend Applicability Date for Fee Disclosure

The Department of Labor's (DOL) Employee Benefits Security Administration (EBSA) issued a final rule that…

Automatic-Enrollment IRAs - Coming to a Business Near You

"Automatic-Enrollment IRAs; Coming to a Business Near You" recently authored by Ben Norquist, CPC, CISP…

DOL's EBSA to Extend Applicability Dates for Fee Disclosure Rules

On June 1, 20111, the Department of Labors (DOL's) Employee Benefits Security Administration (EBSA) published…

Update: IRS Comments on Carryback 2010 QCDs

As part of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act, the IRA…

The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act Becomes Law

On Friday, December 17, 2010, President Obama signed the Tax Relief, Unemployment Insurance Reauthorization, and…

Tax Compromise and Year-End Roth Conversion Implications

On Monday, December 6, 2010, President Obama announced that his administration had reached a tentative…

2010 IRA Contribution Deadline - April 18, 2011

The deadline for making Traditional and Roth IRA contributions for tax year 2010 is April…

IRS Releases Notice 2010-84 "In-Plan" Roth Conversion Guidance

As anticipated, the IRS has issued additional guidance on the new in-plan Roth conversion option…

IRS Posts In-Plan Conversion Information

The IRS has posted to its website information regarding "in-plan conversions", including information as to…

DOL Issues New Proposed Regulations on Definition of Fiduciary

On October 21, 2010, the Department of Labor Employee Benefits Security Administration (EBSA) issued new…

President Obama Signs In-Plan Roth Conversion Legislation

H.R. 5297, the Small Business Jobs Act of 2010, was signed into law by President…

President Obama's Signature on In-Plan Roth Legislation Imminent

H.R. 5297, the Small Business Jobs Act of 2010, has been passed by both the…

Fee Disclosure Interim Final Regulations Issued

On July 15, 2010, the Department of Labor Employee Benefits Security Administration (EBSA) issued interim…

2011 HSA COLAs Issued: Amounts Unchanged From 2010

The IRS recently issued Revenue Procedure 2010-22 to announce the 2011 cost-of-living adjustments (COLAs) applicable…

Tax Filing/IRA Contribution Deadline Postponed for Certain Residents of Massachusetts, Rhode Island, New Jersey, and West Virginia

Due to recent storms and flooding, President Obama has declared several counties in Massachusetts, Rhode…

DOL Issues Investment Advice

On Friday, February 26th, 2010, the Department of Labor issued proposed investment advice regulations. The…

Financial Advisor Magazine Article Spotlights the Roth Conversion Optimizer

Mr. Ben Norquist, Founder and President of Convergent Retirement Plan Solutions, was recently interviewed for…

IRS Releases Notice 2009-82

On September 24, 2009, the IRS issued time-sensitive guidance concerning the 2009 waiver of the…

Obama Administration Announces

In an announcement issued by President Barack Obama and Secretary Tim Geithner on September 5,…

IRS Guidance on Employer Plan-to-Roth IRA Rollovers

Notice 2009-75, released on September 8, 2009, describes the federal income tax consequences of rollovers…

President Signs Bill That Modifies the Federal Thrift Savings Plan

On June 22, 2009, President Obama signed H.R. 1256, the Family Smoking Prevention and Tobacco…

Wall Street Journal Article on Roth Conversion

Mr. Ben Norquist, Founder and President of Convergent Retirement Plan Solutions, was recently interviewed for…

FRC Retirement Forum

Mr. Ben Norquist, Founder and President of Convergent Retirement Plan Solutions, participated on a panel…

Pershing Insight Conference

Mr. Ben Norquist, Founder and President of Convergent Retirement Plan Solutions, along with Beverly Flaxington,…

Immediate Elimination of Conversion Eligibility Requirements Proposed

H.R 2814, proposed by Rep. Joseph Pitts (R-PA), would eliminate the $100,000 conversion income limit…

IRS Releases Comprehensive Auto Enrollment Guidance

Final regulations regarding automatic enrollment arrangements were published February 24th, 2009. These regulations affect 401(k),…

Roth IRA Conversions—A Golden Opportunity for Advisors and Clients

Imminent changes to the Roth IRA rules will open the door to more than $1…

Convergent Retirement Plan Solutions, LLC,of Brainerd, MN, and Archimedes Systems, Inc. of Waltham, MA, have jointly developed a new web-based tool designed to help advisors identify optimal roth conversion ratio.

Convergent and Archimedes Systems, Inc. of Waltham, MA, announced today that they have jointly developed…

Final Investment Advice Regulations Published, But Wait. . .

Final investment advice regulations were published in theFederal Registeron January 21, 2009, but not before…

IRS Releases Notice 2009-9

On Friday, January 09, 2009, the IRS released Notice 2009-9. The notice provides guidance to…

President Bush Signs RMD Legislation

H.R. 7327, the Worker, Retiree and Employer Recovery Act of 2008 was signed into law…

No Relief for 2008 RMDs

Treasury Assistant Secretary for Legislative Affairs Kevin Fromer explained in a letter to Congressman George…

President Bush's Signature on 2009 RMD Relief Imminent

H.R. 7327, the Worker, Retiree and Employer Recovery Act of 2008 is awaiting President Bush's…

Pension Relief Legislation

On Thursday, December 11, 2008, the U.S. Senate passed pension relief legislation affecting both IRAs…

403(b) Relief

On Thursday, December 11, 2008, the IRS issued Notice 2009-3 providing temporary relief during 2009…

DOL Issues IRA/401(k) Advice Guidance

On August 22, 2008, the Department of Labor (DOL) published three significant documents pertaining to…

Convergent Retirement Plan Solutions, LLC Announces the Addition of SEI and The Calvert Group to its Growing List of IRA Clients

Brainerd, MN - July 10, 2008 - Convergent Retirement Plan Solutions, LLC announced that it…

The HEART Act Provides Tax Relief For Military

On June 17, 2008, President Bush signed into law the Heroes Earnings Assistance and Relief…

Ben Norquist to present at FRC Retirement Conference

Mr. Ben Norquist, President and CEO of Convergent Retirement Plan Solutions, will be among industry…

Relief for Direct Deposit of Economic Stimulus Payments Made to IRAs and Other Tax-Favored Account

On April 30, 2008, the IRS released Announcement 2008-44 which allows for Economic Stimulus Payments…

PPA Guidance Issued by IRS

On March 5, 2008, the IRS released Notice 2008-30. This notice contains guidance on distribution-related…

IRS Issues 403(b) Guidance

On November 27, 2007, the IRS issued the much-anticipated, follow-up 403(b) guidance in the form…

At Last . . . Final QDIA Regulations Issued

On October 24, 2007, the Department of Labor (DOL) published the long-awaited final regulations on…

Final 403(b) Regulations Issued

On July 23, 2007, the IRS issued the much anticipated final 403(b) regulations. The final…

Final Roth Regulations Issued

On April 27, 2007, the IRS released final regulations on the distribution and taxation of…

IRS Releases Final 415 Regulations

On April 4, 2007, the IRS issued final regulations governing Internal Revenue Code Section (IRC…

PPA Guidance Issued by IRS

On January 10, 2007, the IRS released IRS Notice 2007-7. This notice contains guidance on…

President Bush Signed the Tax Relief and Health Care Act of 2006

On December 20, 2006, President Bush signed the Tax Relief and Health Care Act of…

President Bush Signs The Pension Protection Act of 2006 Into Law!

On August 17, 2006, President Bush signed the Pension Protection Act of 2006 into law.…

President Bush Signs the Heroes Earned Retirement Opportunities (HERO) Act

President Bush signed The Heroes Earned Retirement Opportunities (HERO) Act (H.R. 1499) into law on…

The Tax Increase Prevention and Reconciliation Act Will Open the Roth IRA Conversion Flood Gate

On May 17, 2006 , President Bush signed the Tax Increase Prevention and Reconciliation Act…

FDIC Insurance Limits to Increase April 1

The Federal Deposit Insurance Corporation (FDIC) approved final rules that will raise the deposit insurance…

Baucus Bill Will Aid Retirement Savings, National Savings to Improve America's Economic Competitiveness

Washington, DC -- Legislation has been introduced by U.S. Senator Max Baucus (D-Mont.), Ranking Democrat…

IRS Offers Relief to Employers with SIMPLE IRA Plan

The Employee Plans division of the IRS has announced that it is offering employers with…

Mr. Norquist to Speak at NTSAA National Conference

Ben Norquist, CPC, CISP, president of Convergent Retirement Plan Solutions, LLC will present "Beyond Investments:…

Convergent and Archimedes Join Forces to Create Web Retirement Income Planning Toolkit

Convergent Retirement Plan Solutions, LLC of Brainerd, MN, and Archimedes Systems, Inc. of Waltham, MA,…

IRS Issues Final Roth 401(k) Regulations

Following months of industry anticipation, the IRS issued final Roth 401(k) regulations on December 30,…

Gulf Opportunity Zone Act (GOZA)

On December 21, 2004 , President Bush signed theGulf Opportunity Zone Act (GOZA) of 2005.…

IRS Releases Notice 2005-92 Providing Guidance On Katrina Legislation

The IRS has released Notice 2005-92 to offer guidance on the changes brought about by…

Temporary Regulations For IRA Annuity Conversions To Roth IRA

The IRS has released temporary regulations to address the issue of determining the fair market…

RMDs With Qualified Disclaimers Clarified By IRS

In Revenue Ruling 2005-36 , the IRS has helped to eliminate some of the about…

IRS To Increase EP Scrutiny

Carol Gold, director of Employee Plans, Tax-Exempt and Government Entities Division , recently informed the…

Roth 401(k)

The Roth IRA took the retirement world by storm in 1998 with benefits such as…

Orphan Plans

In response to requests from financial organizations, recordkeepers and plan participants the Department of Labor…

Safe Harbor Rollover

March 28, 2005 is the effective date for the new safe-harbor rollover requirements forcing employers…