Trade Associations
Here's a look at documents from national and international trade associations
Featured Stories
Santa Clarita Nurses Ratify Contract With Strong Measures to Improve Patient Safety and Nurse Retention
OAKLAND, California, July 11 -- The California Nurses Association issued the following news release:
* * *
Santa Clarita nurses ratify new contract with strong measures to improve patient safety and nurse retention
RNs at Henry Mayo Newhall Hospital approve new three-year contract
*
Registered nurses at Henry Mayo Newhall Hospital in Valencia, Calif., voted overwhelmingly in favor of ratifying a new three-year contract on July 9, winning protections to improve patient safety and nurse retention, announced California Nurses Association/National Nurses United (CNA/NNU).
"We, the nurses of Henry
... Show Full Article
OAKLAND, California, July 11 -- The California Nurses Association issued the following news release:
* * *
Santa Clarita nurses ratify new contract with strong measures to improve patient safety and nurse retention
RNs at Henry Mayo Newhall Hospital approve new three-year contract
*
Registered nurses at Henry Mayo Newhall Hospital in Valencia, Calif., voted overwhelmingly in favor of ratifying a new three-year contract on July 9, winning protections to improve patient safety and nurse retention, announced California Nurses Association/National Nurses United (CNA/NNU).
"We, the nurses of HenryMayo, are excited to have reached a deal with the hospital," said Clarissa Vela, RN in palliative care. "We strongly feel that this contract meets the needs of our patients and community by retaining experienced staff and recruiting new staff."
Highlights of the contract include:
* Benefits to improve recruitment and retention of staff nurses
* Language that improves safe staffing and nurse advocacy
* Improvement of access to bereavement leave
* Improvement to protected leaves
The new pact covers the period July 9, 2025 to Jan. 22, 2028.
"This contract is a reflection of how fiercely nurses are willing to fight to continue that legacy of patient advocacy," said Monique Avalos, RN in the telemetry unit. "This contract not only aids us nurses, but it truly has an impact on our patients and their care."
Nurses held a rally in April to express their concerns about staffing and working conditions.
CNA represents more than 600 nurses at Henry Mayo Newhall Hospital.
California Nurses Association/National Nurses United is the largest and fastest-growing union and professional association of registered nurses in the nation with more than 100,000 members in more than 200 facilities throughout California and more than 225,000 RNs nationwide.
* * *
Original text here: https://www.nationalnursesunited.org/press/santa-clarita-nurses-ratify-new-contract-with-strong-measures-to-improve-patient-safety-and-nurse-retention
SBIA Applauds Senate Introduction of Investing in Main Street Act
WASHINGTON, July 11 -- The Small Business Investor Alliance issued the following news release:
* * *
SBIA Applauds Senate Introduction of Investing in Main Street Act
Legislation would ensure that small and mid-sized businesses across the country can access the capital they need to compete and grow.
*
WASHINGTON, DC (July 10, 2025) - The Small Business Investor Alliance (SBIA) commends U.S. Senators Todd Young (R IN), Ruben Gallego (D AZ), James Risch (R-ID) and Tammy Duckworth (D-IL) for introduction of the Investing in Main Street Act of 2025. The legislation would amend the Small Business
... Show Full Article
WASHINGTON, July 11 -- The Small Business Investor Alliance issued the following news release:
* * *
SBIA Applauds Senate Introduction of Investing in Main Street Act
Legislation would ensure that small and mid-sized businesses across the country can access the capital they need to compete and grow.
*
WASHINGTON, DC (July 10, 2025) - The Small Business Investor Alliance (SBIA) commends U.S. Senators Todd Young (R IN), Ruben Gallego (D AZ), James Risch (R-ID) and Tammy Duckworth (D-IL) for introduction of the Investing in Main Street Act of 2025. The legislation would amend the Small BusinessInvestment Act of 1958 to align banking and small business investment laws.
Specifically, the bill would enable banks and federal savings associations to invest up to 15% of their capital and surplus into Small Business Investment Companies (SBICs), a marked increase from the current 5% cap, correcting a long-standing statutory inconsistency between bank law and small business investment law. By addressing this regulatory roadblock, the legislation will empower small businesses to access the funding they need to create jobs, innovate, and drive economic growth in their communities.
"This bill offers a smart solution to an accidental regulatory barrier that limits investment in American small businesses," said SBIA President Brett Palmer. "By updating outdated regulations, this legislation will help funnel vital funding into our nation's small businesses - economic engines that drive two-thirds of U.S. job creation. We thank Senator Young, Senator Gallego, Senator Risch and Senator Duckworth for their leadership and urge swift Senate passage."
Key Facts
* House bill H.R. 754 passed unanimously in the House on February 24, 2025.
* This reform fixes conflicting laws that currently limit investments into SBICs, allowing banks and federal savings associations to invest up to 15% of their capital and surplus into SBICs.
* By aligning banking and small business investment laws, the bill resolves outdated regulatory inconsistencies that have restricted capital flow to SBICs - without costing taxpayers a dime.
* Passage would permit banks to deploy significantly more capital into SBICs, powering small business growth, job creation, and innovation nationwide.
SBIA urges the Senate to advance this legislation quickly to ensure that small and mid-sized businesses across the country can access the capital they need to compete and grow.
What is an SBIC?
SBICs are federally licensed, privately managed investment funds that provide patient, flexible capital to qualifying small businesses. With more than 300 active SBICs managing over $43 billion in capital, the program has a long track record of success in supporting businesses in manufacturing, healthcare, technology, and services sectors. SBIC-backed businesses have created or sustained millions of jobs and contributed to the growth of countless industries.
About the Small Business Investor Alliance (SBIA)
The Small Business Investor Alliance (SBIA) is the premier organization of lower middle market private equity funds and investors. SBIA works on behalf of its members as a tireless advocate for policies that promote competitive markets and robust domestic investment for growing small businesses. SBIA has been playing a pivotal role in promoting the growth and vitality of the private equity industry for over 60 years. For more information, visit www.SBIA.org or call (202) 628-5055.
* * *
Original text here: https://sbia.org/2025/07/10/sbia-applauds-senate-introduction-of-investing-in-main-street-act/
[Category: Business]
Military Officers Association: What the 'Megabill' Means for Servicemembers, Veterans, and Military Families ... and What's Next
WASHINGTON, July 11 -- The Military Officers Association of America issued the following news:
* * *
What the 'Megabill' Means for Servicemembers, Veterans, and Military Families ... and What's Next
By Kevin Lilley
When it comes to key MOAA legislative priorities, the biggest news from the so-called "megabill" signed into law July 4 may have been what wasn't included.
When the House narrowly passed the Senate version of the legislation July 3 without any changes, it ended the immediate threat to the "90-10 rule" - a critical protection for veteran education benefits that, if repealed, would've
... Show Full Article
WASHINGTON, July 11 -- The Military Officers Association of America issued the following news:
* * *
What the 'Megabill' Means for Servicemembers, Veterans, and Military Families ... and What's Next
By Kevin Lilley
When it comes to key MOAA legislative priorities, the biggest news from the so-called "megabill" signed into law July 4 may have been what wasn't included.
When the House narrowly passed the Senate version of the legislation July 3 without any changes, it ended the immediate threat to the "90-10 rule" - a critical protection for veteran education benefits that, if repealed, would'veleft student-veterans vulnerable to aggressive recruiting tactics from for-profit colleges. The House version would've replaced the rule with a new, untested system of protections, at the cost of $1.6 billion over 10 years. MOAA worked with fellow advocacy groups and stakeholders to protect the current rule.
The new law includes $150 billion in DoD funding, some of which addresses MOAA focus areas:
* Better BAH: $2.9 billion in supplemental funds for the Basic Allowance for Housing (BAH), though details on how the funds will be spent remain unclear. MOAA has fought to restore BAH to 100% of projected housing costs.
* Unaccompanied Housing: $1 billion for Army, Navy, Air Force, and Space Force housing, and more than $230 million to support the Marine Corps Barracks 2030 program.
* Health Care: $2 billion in additional funding for the Defense Health Program.
* Child Care: $100 million in child care fee assistance, and another $62 million to modernize staffing at DoD child care centers.
* More Spouse and Family Support: $100 million for Impact Aid payments (designed to assist school districts with large DoD populations), and $10 million for military spouse professional licensure.
Now What?
With the megabill now law, Congress already has resumed work on the two more typical tracks that set agency budgets and agendas for the fiscal year - authorization and appropriation.
DoD: Separate from the megabill, DoD has requested nearly $850 billion in funding for FY 2026. The House is expected to vote on its DoD appropriations bill, which allocates $831.5 billion, in mid-July; the bill passed the House Appropriations Committee last month. The FY 2026 National Defense Authorization Act (NDAA) should also make strides in July before lawmakers leave for summer recess in early August.
VA: The House version of the VA appropriations bill passed the chamber June 25, becoming the first appropriations bill to clear either chamber of Congress. It was referred to the Senate Appropriations Committee on June 30. The VA does not have an annual authorization-bill vehicle for legislative changes; the last piece of omnibus legislation, the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act, passed in December in the final days of the 118th Congress and was signed into law Jan. 2.
Keep up with the latest on these pieces of legislation, including MOAA's work to ensure the bills preserve service-earned benefits while maintaining a strong all-volunteer force, by visiting our news page.
About the Author
Kevin Lilley
Lilley serves as MOAA's digital content manager. His duties include producing, editing, and managing content for a variety of platforms, with a concentration on The MOAA Newsletter and MOAA.org. Follow him on X: @KRLilley
* * *
Original text here: https://www.moaa.org/content/publications-and-media/news-articles/2025-news-articles/health-care-and-earned-benefits/what-the-megabill-means-for-servicemembers,-veterans,-and-military-families-and-what-comes-next/
[Category: National Defense]
From MOAA's President: VA Staffing Cuts and Your Earned Benefits
WASHINGTON, July 11 -- The Military Officers Association of America issued the following statement on July 9, 2025, by President and CEO Brian T. Kelly:
* * *
From MOAA's President: VA Staffing Cuts and Your Earned Benefits
By Brian T. Kelly
From the very start of the Department of Government Efficiency (DOGE) reviews of the VA and early announcements indicating that workforce reductions could reach as high as 80,000, MOAA has maintained a clear and consistent position.
We absolutely support the responsible pursuit of finding savings and efficiencies within the federal workforce. As fellow
... Show Full Article
WASHINGTON, July 11 -- The Military Officers Association of America issued the following statement on July 9, 2025, by President and CEO Brian T. Kelly:
* * *
From MOAA's President: VA Staffing Cuts and Your Earned Benefits
By Brian T. Kelly
From the very start of the Department of Government Efficiency (DOGE) reviews of the VA and early announcements indicating that workforce reductions could reach as high as 80,000, MOAA has maintained a clear and consistent position.
We absolutely support the responsible pursuit of finding savings and efficiencies within the federal workforce. As fellowtaxpayers, why wouldn't we be supportive of efficient government? At the same time, MOAA has been unwavering in its stance that cost-cutting measures must never compromise the earned benefits guaranteed to our veterans and retirees. These benefits are not budget line items -- they are solemn promises made in recognition of service and sacrifice.
While the loss of 30,000 VA positions will allow the department to avoid reduction-in-force measures that could have more than doubled those staffing cuts, the true measure of its impact lies not in these numbers, but in the outcomes: the quality, accessibility, and timeliness of care and benefits delivered to veterans.
As of now, the full impact of these staffing decisions remains unclear. The final report card cannot be issued until we see how they affect veterans' experiences with the VA system.
Will appointments be harder to schedule? Will claims take longer to process? Will specialized care become less accessible? These are the real questions veterans and their families are asking -- and MOAA is committed to finding the answers. We will work alongside our partners in the veterans service organization (VSO) community to advocate for accountability and transparency throughout the process.
Just as we remain vigilant in ensuring that the legislation MOAA supports is implemented faithfully and effectively, we will continue to track VA performance and push for a streamlined department that still puts veterans first, ensuring they receive the care and benefits they've earned without compromise.
About the Author
Lt. Gen. Brian T. Kelly, USAF (Ret)
Lt. Gen. Brian T. Kelly, USAF (Ret), is MOAA's president and CEO. He retired from the Air Force in 2022 after more than three decades of service.
* * *
Original text here: https://www.moaa.org/content/publications-and-media/news-articles/2025-news-articles/recommended-reads/from-moaas-president-va-staffing-cuts-and-your-earned-benefits/
[Category: National Defense]
ENA Announces Jeff Evans as Emergency Nursing 2025 Keynote Speaker
SCHAUMBURG, Illinois, July 11 -- The Emergency Nurses Association issued the following news:
* * *
ENA Announces Jeff Evans as Emergency Nursing 2025 Keynote Speaker
Evans' tales from mountain tops and emergency departments carry leadership and teamwork messages
*
From the emergency department to the highest mountain tops in the world, Jeff Evans continues to pursue unique adventures - and, in September, his journey takes him to a "special place surrounded by my people" at Emergency Nursing 2025 in New Orleans.
On Thursday, ENA announced Evans as the keynote speaker to lead off the biggest
... Show Full Article
SCHAUMBURG, Illinois, July 11 -- The Emergency Nurses Association issued the following news:
* * *
ENA Announces Jeff Evans as Emergency Nursing 2025 Keynote Speaker
Evans' tales from mountain tops and emergency departments carry leadership and teamwork messages
*
From the emergency department to the highest mountain tops in the world, Jeff Evans continues to pursue unique adventures - and, in September, his journey takes him to a "special place surrounded by my people" at Emergency Nursing 2025 in New Orleans.
On Thursday, ENA announced Evans as the keynote speaker to lead off the biggestevent dedicated to emergency nursing. Evans brings with him messages about leadership, teamwork and trust developed by his blended experience of nearly two decades working in emergency departments and a quarter-century of scaling the globe's tallest peaks, including Mount Everest.
"When I come to New Orleans and I get on that stage with my colleagues, my peers, I can look them in the eyes and I can relate in a way that allows me to share my stories in an even more authentic way," Evans, a practicing emergency department physician's assistant, said in an ENA Podcast interview. "Though these stories are taking place on these big mountains, it's truly relatable to how we all function independently."
Stories of expeditions, such as guiding the only blind climber to ever reach Everest's summit, and life as a medic at high altitudes and in war zones, shape perspectives he believes can help make for better, more vibrant people, Evans shared.
ENA President Ryan Oglesby, PhD, MHA, RN, CEN, CFRN, NEA-BC, looks forward to hearing Evans connect the seemingly distinct worlds of the emergency department and mountaineering around themes which resonate with ED nurses.
"I can only imagine what it requires to climb to the heights Jeff has in his career, but I recognize trust, communication and overcoming adversity is needed among teams and leaders - just as it does to make an emergency department the best it can be," Oglesby said.
Emergency Nursing 2025 takes place in New Orleans Sept. 17-20. For more information and to register, visit ena.org/EN25. Check out jeffbevans.com to learn about adventures.
The Emergency Nurses Association is the premier professional nursing association dedicated to defining the future of emergency nursing through advocacy, education, research, innovation, and leadership. Founded in 1970, ENA has proven to be an indispensable resource to the global emergency nursing community. With nearly 45,000 members worldwide, ENA advocates for patient safety, develops industry-leading practice standards and guidelines and guides emergency health care public policy. ENA members have expertise in triage, patient care, disaster preparedness, and all aspects of emergency care. Additional information is available at www.ena.org.
* * *
Original text here: https://www.ena.org/news-publications/newsroom/ena-announces-jeff-evans-emergency-nursing-2025-keynote-speaker
[Category: Nursing]
Canadian Agricultural Tractor Sales Rise Slightly in June 2025 as U.S. Sales Continue to Drop
MILWAUKEE, Wisconsin, July 11 (TNSrep) -- The Association of Equipment Manufacturers issued the following news:
* * *
Canadian Agricultural Tractor Sales Rise Slightly in June 2025 as U.S. Sales Continue to Drop
*
Milwaukee (July 10, 20205) - According to recent data from the Association of Equipment Manufacturers (AEM), Canadian sales of 4-wheel drive tractors grew 24.7% year-to-date in June 2025 compared to the year before. Total Canadian sales of agricultural tractors were up 1.6% year-to-date in June 2025.
U.S. sales of agricultural tractors and combines didn't see any increases in June
... Show Full Article
MILWAUKEE, Wisconsin, July 11 (TNSrep) -- The Association of Equipment Manufacturers issued the following news:
* * *
Canadian Agricultural Tractor Sales Rise Slightly in June 2025 as U.S. Sales Continue to Drop
*
Milwaukee (July 10, 20205) - According to recent data from the Association of Equipment Manufacturers (AEM), Canadian sales of 4-wheel drive tractors grew 24.7% year-to-date in June 2025 compared to the year before. Total Canadian sales of agricultural tractors were up 1.6% year-to-date in June 2025.
U.S. sales of agricultural tractors and combines didn't see any increases in June2025. Total agricultural tractor sales fell 4.4%, while combine sales dipped 43.7% compared to June 2024.
"The ongoing slump in U.S. combine and tractors sales demonstrates the market challenges facing the agricultural sector," said AEM Senior Vice President Curt Blades. "We know farmers are hesitant to make major investments with global trade instability, high interest rates, and increased input prices. We're encouraged by Canada's continued strong performance throughout these summer months. The passage of the One Big Beautiful Bill Act is also a significant step forward for the agricultural equipment industry."
The Ag Tractor and Combine reports can be found on the AEM Market Share Statistics page. The U.S. report can be downloaded from this page (https://www.aem.org/market-share-statistics/us-ag-tractor-and-combine-reports), while the Canadian report is available for download here (https://www.aem.org/market-share-statistics/canadian-ag-tractor-combine-reports).
About AEM
The Association of Equipment Manufacturers (AEM) is North America's premier trade organization representing off-road equipment manufacturers and their value chain partners. With a rich history spanning over 125+ years, AEM serves more than 1,100 members companies across 200+ product lines in multiple sectors including construction, agriculture, mining, utility, and forestry. AEM supports an industry that contributes approximately $316 billion annually to the U.S. economy while sustaining 2.3 million jobs. Through advocacy, market intelligence, and industry collaboration, AEM works to advance the interests of equipment manufacturers and their partners in the global marketplace.
* * *
Original text here: https://newsroom.aem.org/canadian-agricultural-tractor-sales-rise-slightly-in-june-2025-as-us-sales-continue-to-drop/
[Category: Business]
AICPA Requests Guidance on SECURE 2.0 Roth Mandated Catch-Up Contributions
NEW YORK, July 11 -- The Association of International Certified Professional Accountants issued the following news release:
* * *
AICPA Requests Guidance on SECURE 2.0 Roth Mandated Catch-Up Contributions
*
Washington, D.C. (July 10, 2025) - In a letter submitted to the Department of the Treasury and Internal Revenue Service (IRS), the American Institute of CPAs (AICPA) requested additional guidance related to catch-up contributions designated as Roth contributions within Section 603 of the SECURE 2.0 Act of 2022, which was signed into law as part of the Consolidated Appropriations Act of 2023.
... Show Full Article
NEW YORK, July 11 -- The Association of International Certified Professional Accountants issued the following news release:
* * *
AICPA Requests Guidance on SECURE 2.0 Roth Mandated Catch-Up Contributions
*
Washington, D.C. (July 10, 2025) - In a letter submitted to the Department of the Treasury and Internal Revenue Service (IRS), the American Institute of CPAs (AICPA) requested additional guidance related to catch-up contributions designated as Roth contributions within Section 603 of the SECURE 2.0 Act of 2022, which was signed into law as part of the Consolidated Appropriations Act of 2023.In January, 2025, Treasury and the IRS issued REG-101268-24, which included guidance reflecting the statutory changes made by section 603 of SECURE 2.0. Those changes include the requirement that catch-up contributions made by certain catch-up eligible participants must be designated as Roth contributions, otherwise referred to as the Roth mandate.
The Roth mandate affects certain employees participating in employer-sponsored retirement plans who are eligible to make catch-up contributions and whose wages meet a specific income threshold.
Safe harbor for Form W-2 reliance
The AICPA recommends that Treasury and the IRS create a safe harbor that allows plan administrators to rely on W-2 wage information when determining if employees exceed the catch-up wage threshold for the purposes of the Roth mandate. If such a safe harbor is unable to be adopted, clear guidance is suggested related to scenarios involving predecessor employers and other third-party arrangements, including relief for non-compliance that may result and otherwise be unavoidable in reasonable administration of plans using Form W-2 information for purposes of determining which employees are subject to the Roth mandate.
Application to disregarded entities
A disregarded entity with employees is generally required to file employment tax returns using its own employer identification number and is treated as an employer, regardless of its disregarded status for income tax purposes. The AICPA recommends that Treasury and the IRS articulate a position on whether a disregarded entity is treated as a separate "employer sponsoring the plan" for purposes of Prop. Reg. 1.414(v)-2(b)(3) and (4).
"Post-SECURE 2.0, employers and plan administrators will need clear guidance to ensure compliance of the law regarding Roth-mandated catch-up contributions," says Kristin Esposito, AICPA Director, Tax Policy & Advocacy. "Our recommendations to the regulations proposed by Treasury and the IRS, if adopted, will make it easier for plan administrators to implement the law."
About the American Institute of CPAs
The American Institute of CPAs (AICPA) is the world's largest member association representing the CPA profession, with 397,000 members and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education, and consulting. A founding member of the Association of International Certified Professional Accountants, the AICPA sets ethical standards for the profession, attestation standards, and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state, and local governments. It develops and grades the Uniform CPA Examination, offers specialized credentials, partners across the profession to build future talent, and drives continuing education to advance the vitality, relevance, and quality of the profession.
Ms. Helen Morrison, Benefits Tax Counsel, Department of the Treasury, 1500 Pennsylvania Ave., NW, Washington, DC 20220
Ms. Laura Warshawsky, Acting Associate Chief Counsel (EEE), Internal Revenue Service, 1111 Constitution Ave., NW, Washington, DC 20224
Re: Proposed Regulations Related to Section 603 of the SECURE 2.0 Act with Respect to Roth-Mandated Catch-Up Contributions [REG-101268-24]
Dear Mses. Morrison and Warshawsky:
The American Institute of CPAs (AICPA) appreciates the efforts of the Department of the Treasury ("Treasury") and the Internal Revenue Service (IRS) to address the need for guidance related to plans that provide or intend to provide, catch-up contributions designated as Roth contributions, as enacted in Section 603 of the SECURE 2.0 Act of 2022 (SECURE 2.0), signed into law on December 29, 2022, as part of the Consolidated Appropriations Act of 2023./1
On January 10, 2025, Treasury and the IRS issued [REG-101268-24], including Prop. Reg. Sec. 1.414(v)-(2)2 (the "Proposed Regulations") to provide guidance reflecting the statutory changes made by section 603 of SECURE 2.0, including the requirement that catch-up contributions made by certain catch-up eligible participants must be designated as Roth contributions ("Roth Mandate").
The AICPA recommends that Treasury and the IRS address the following items as they relate to the Proposed Regulations:
I. Safe harbor for Form W-2 reliance
II. Application to disregarded entities
Background
Section 603 of SECURE 2.0 amends section 414(v) to add section 414(v)(7). Section 414(v)(7)(A) provides that catch-up contributions made by certain catch-up eligible participants (those whose wages as defined in section 3121(a) for the preceding calendar year from the employer sponsoring the plan exceeded $145,000 (as adjusted for changes in the cost of living) must be designated Roth contributions. The Proposed Regulations provide general rules applicable to the Roth Mandate under section 414(v)(7)(A).
Proposed Reg. Sec. 1.414(v)-2(a)(2) defines wages as those "defined in section 3121(a) for purposes of the taxes imposed by sections 3101(a) and 3111(a)" (increased for changes in the cost of living) for the preceding calendar year from the employer sponsoring the plan. Proposed Reg. Sec. 1.414(v)-(2)(b)(3) clarifies that the term "employer sponsoring the plan" means the participant's common law employer contributing to the plan and does not include other entities that are treated as a single employer with a catch-up eligible participant's common law employer under section 414(b), (c), (m), or (o)./3 Footnote 14 in the preamble to the Proposed Regulations provides that Prop. Reg. Sec. 1.414(v)-(2)(b)(3) "applies even if responsibilities under chapter 21 of the Internal Revenue Code (IRC or Code) are imposed on a third party, such as a section 3401(d) statutory employer, a section 3504 agent, a section 3121(s) common paymaster, a section 3511 certified PEO, or a section 3512 motion picture project employer."
I. Safe harbor for Form W-2 reliance
Overview
Section 414(v)(7)(A) defines wages as those "defined in section 3121(a)." Proposed Reg. Sec. 1.414(v)-2(a)(2) defines wages as those "defined in section 3121(a) for purposes of the taxes imposed by sections 3101(a) and 3111(a)." The term "wages" is defined in section 3121(a) for social security and Medicare (collectively FICA) tax purposes as all remuneration for employment, including wages subject to the excise taxes imposed by sections 3101 and 3111. Sections 3101(a) and 3111(a) impose social security tax (i.e., OASDI) on the employee and employer, respectively, subject to the wage base limitation ($176,100 in 2025). Sections 3101(b) and 3111(b) impose the Medicare tax on the employee and employer, respectively, with no limitation on wages subject to Medicare taxation.
For purposes of social security taxation of wages, section 3121(a)(1) provides that, in the case of taxes imposed by sections 3101(a) and 3111(a) (employee and employer social security taxes, respectively), if an employer (herein referred to as a successor employer) "during any calendar year acquires substantially all the property used in a trade or business of another employer (hereinafter referred to as a predecessor), or used in a separate unit of a trade or business of a predecessor, and immediately after the acquisition employs in his trade or business an individual who immediately prior to the acquisition was employed in the trade or business of such predecessor, then, for the purpose of determining whether the successor employer has paid remuneration [...] with respect to employment equal to the contribution and benefit base [...], to such individual during such calendar year, any remuneration [...] with respect to employment paid [...] to such individual by such predecessor during such calendar year and prior to such acquisition shall be considered as having been paid by such successor employer."
Revenue Procedure 2004-53 provides predecessor-successor employers with two procedures -- a standard procedure and an alternate procedure -- for preparing and filing Forms W-2 and other applicable payroll filings. Section 4.01 of Rev. Proc. 2004-53 provides that under the standard procedure, the predecessor performs all the reporting duties for the wages and other compensation it pays. The successor, under the standard procedure, performs all the reporting duties for the wages and other compensation it pays. In other words, under the standard procedure, an employee who is initially employed by the predecessor employer and then transfers to the successor employer in the same calendar year (a "transferred employee") will receive two Forms W-2, one from each of the predecessor and successor employers, reflecting only the compensation paid directly by those respective employers.
Section 5.01 of Rev. Proc. 2004-53 provides that under the alternate procedure, if the predecessor and successor so agree, the predecessor will be relieved from furnishing Forms W 2 to any transferred employees, with the successor reporting wages paid, and taxes withheld, by both the predecessor and the successor. As such, under the alternate procedure, a transferred employee will receive a single Form W-2 from the successor employer, comprising all compensation paid during the year by both the predecessor and successor employers.
Recommendation
The AICPA recommends that Treasury and the IRS provide a safe harbor permitting all plan administrators to rely on wage information as reported on Forms W-2 when determining whether employees have exceeded the catch-up wage threshold for purposes of the Roth Mandate.
Absent the inclusion of a safe harbor, we suggest that Treasury and the IRS provide specific guidance for scenarios involving predecessor-employers, and other third-party arrangements (e.g., common paymasters, professional employer organizations (PEOs), and certified professional employer organizations (CPEOs)), including, but not limited to, relief for noncompliance that may result and otherwise be unavoidable in reasonable administration of plans using Form W-2 information for purposes of determining which employees are subject to the Roth Mandate.
Analysis
The statutory definition of wages for purposes of the Roth Mandate encompasses the FICA definition, but the Proposed Regulations narrow this definition to the OASDI component of FICA, effectively limiting the amounts taken into account to wages subject to the OASDI wage threshold. This definition in conjunction with idiosyncrasies of reporting will result in some anomalies on which further guidance would be helpful. Further, because these anomalies exist, employers should be permitted to rely on the wages reported in Box 3 of Form W-2 even when the amount reported varies from the social security wages paid by the common-law employer.
There are scenarios where an employee Form W-2 does not accurately represent the actual wages paid by the issuing employer or the wages paid by the common law employer subject to the rules of section 414(v)(7)(A). For example, in successor employer scenarios, regardless of whether the standard or alternate procedure is used, the Form W-2 issued by the successor employer will generally not have accurate information regarding social security wages it paid. However, plan administrators generally do not have ready access to payroll records or have limited experience with and capacity for reviewing such records to determine wages, such that they must rely on Form W-2 information when determining wages paid. Reliance on Forms W-2, particularly in situations involving successor employers and three-party arrangements, can lead to improper application of the Roth designation or failure to apply the Roth designation to one or more employees when required.
To illustrate issues of inaccurate representation via Form W-2, consider an example using successor employers. Employees transferred to a successor employer may receive a single Form W-2 for the year of transfer that reports wages from both the predecessor and successor employers, or two Forms W-2, one from each predecessor and successor employers, depending on whether the predecessor and successor use the standard or alternate procedure provided by Rev. Proc. 2004-53. In these successor employer situations, the Form W-2 may inaccurately reflect the wages subject to social security tax paid by the successor employer, leading to improper application of the Roth Mandate, regardless of which procedure is used.
Table: As an example, assume the same facts as Proposed Regulation Sec. 1.414(v)-2(d), Example 4, except the wages paid by Employers F and G are reversed, where Employer F paid $35,000 in wages for 2025 and Employer G paid $155,000 in wages for 2025. Pursuant to Section 3121(a)(1) and Rev. Proc. 2004-53, Employer F is considered a predecessor employer and Employer G is considered a successor employer. The following table illustrates how these amounts are reported on Form W-2 using the standard and alternate procedures in Boxes 3 (social security wages) and 5 (Medicare wages)
Section 3121(a)(1) entitles Employer G, the successor employer, to a credit for the $35,000 in wages already paid by Employer F. If successor Employer G uses the standard procedure, Employer G's Form W-2, Box 3 (social security wages) will only report the $125,200 in wages subject to social security tax that remain for the employee ($160,200 social security wage base, less the $35,000 paid by Employer F and credited to Employer G), despite the fact that Employer G actually paid wages of $155,000, which exceeds the wage threshold. As such, in relying on the Form W-2, Box 3 information, Employer G will fail to apply the Roth Mandate to this employee.
Conversely, if Employers F and G use the alternate procedure, the Form W-2 issued by Employer G will report the full $160,200 in Box 3 for the year (comprising the $35,000 from Employer F plus the remaining $125,200 of wages paid by Employer G up to the social security wage base), indicating that the employee has exceeded the wage threshold under the Proposed Regulation's definition. While the Roth Mandate would be applied correctly in this example given Employer G actually paid $155,000 in wages for the calendar year, which is over the wage in wages and predecessor Employer F had paid the $155,000, Employer G would have incorrectly applied the Roth Mandate for the employee based on the Form W-2. This is one example among many that can result in inconsistent application of the Roth Mandate in successor employer situations, regardless of which procedure is used. While this issue applies in the predecessor-successor employer context, there is also concern regarding inconsistent application of the Roth designation based on use of Form W-2 in other scenarios where a Form W-2 may not accurately reflect wages paid by the employer sponsoring the plan (i.e., the common law employer). These scenarios include fact patterns involving common paymasters, PEOs, and CPEOs, as well as other third parties such as section 3401(d) employers and section 3504 agents.
To address these anomalies, the AICPA recommends that employers be permitted, but not required, to rely on the amount reported in Box 3 of the Form W-2 to determine which employees are subject to the Roth mandate. The AICPA does not believe that the requested safe harbor would be abused by plan administrators, nor will the safe harbor have any real bearing on plan administrators' decision on whether a plan should have a designated Roth feature. Therefore, it is not necessary to include a "pick and stick" requirement for those utilizing the safe harbor.
II. Application to Disregarded Entities
Overview
The entity classification regulations under section 301.7701-2(c)(2)(i) provide that, except as otherwise provided in paragraph(c) of the regulation, a business entity that has a single owner and is not a corporation under paragraph (b) of section 301.7701 of the regulations is disregarded as an entity separate from its owner (a "disregarded entity" or "DRE"). The initial flush language of section 301.7701-2(c) provides that this is the rule "for federal tax purposes." Section 301.7701-3(b) provides that an entity not classified as a corporation that has only one owner may file an election to either be classified as an association or to be disregarded as an entity separate from its owner. The regulations under section 301.7701-3(b)(1)(ii) provide that a domestic entity with a single owner will be disregarded as an entity separate from its owner if it does not otherwise make an election under section 301.7701-3(b)(1)(ii) to be classified as a corporation, as defined in section 301.7701-2(b)(2). These regulations are commonly referred to as the "check the box" regulations.
However, final regulations issued in 2009 provide distinct rules regarding the treatment of disregarded entities for Subtitle C ("Employment Taxes") purposes. Specifically, section 301.7701-2(c)(2)(iv) provides that an entity that is disregarded as an entity separate from its owner for any purpose under section 301.7701-2 is treated as a corporation with respect to Subtitle C, which includes the FICA provisions; thus, the entity is "re-regarded" or is not disregarded. A disregarded entity with employees is generally required to file employment tax returns using its own employer identification number and is treated as an employer, regardless of its disregarded status for income tax purposes.
Section 301.7701-2(c)(2)(iv) does not apply to Subtitle A ("Income Taxes") and therefore does not apply to section 414(v)(7)(A).
Recommendation
The AICPA recommends that Treasury and the IRS articulate a position on whether a disregarded entity is treated as a separate "employer sponsoring the plan" for purposes of Prop. Reg. 1.414(v)-2(b)(3) and (4).
Analysis
The application of the Roth Mandate depends on whether, in the previous year, an individual received wages from "the employer sponsoring the plan" in excess of the applicable threshold. Proposed Reg. 1.414(v)-2(b)(3) states:
For purposes of determining the employer sponsoring the plan with respect to a catch-up eligible participant, the employer is the participant's common law employer. Thus, for purposes of this section, the employer sponsoring the plan does not include other entities that are treated as a single employer with a catch-up eligible participant's common law employer under section 414(b), (c), (m), or (o).
Proposed Reg. 1.414(v)-2(b)(4) states, in part
If an applicable employer plan has more than one employer sponsoring the plan (that is, the plan is sponsored by multiple employers that are aggregated under section 414(b), (c), (m), or (o), or is a multiple employer plan or a multiemployer plan), a catch-up eligible participant's wages for the preceding calendar year from one employer sponsoring the plan are not aggregated with the wages from another employer sponsoring the plan ...
The rules of section 414(b), (c), (m), and (o) treat entities that are otherwise separate legal entities (and separately regarded for Federal tax purposes) as a single employer for purposes of various rules governing qualified retirement plans. The Proposed Regulations would not aggregate these otherwise aggregated entities in determining the amount of wages for purposes of applying the Roth Mandate. However, a disregarded entity is not considered a separate entity for Federal tax purposes (except for employment tax purposes under Subtitle C), and thus the rules of sections 414(b), (c), (m) and (o) would not aggregate a disregarded entity with its owner. This is because the disregarded entity is part of (i.e., one and the same) as its owner for purposes of these rules.
Despite this, as previously indicated, a DRE is considered a separate entity for employment tax purposes. In addition, the proposed regulations also indicate that the "employer sponsoring the plan" is the actual common law employer, determined on a separate legal entity basis. This would suggest that wages paid by the DRE and by its owner (in the case of an employee who works for both entities during the year) would not be combined for purposes of determining the application of the Roth Mandate.
The better reading of the proposed regulations would treat the DRE as a separate entity for purposes of the Roth mandate (based on the first sentence of proposed regulation 1.414(v) 2(b)(3)). However, this is not entirely clear, because the DRE is not considered a separate entity for purposes of subtitle A of the Code (which is where section 414(v) appears). Based on the potential for confusion, we recommend that the final regulations contain an explicit statement regarding the treatment of a DRE and whether it is considered a separate "employer sponsoring the plan" or one and the same with its owner for this purpose.
The AICPA is the world's largest member association representing the accounting profession, with more than 397,000 members in the United States and worldwide, and a history of serving the public interest since 1887. Our members advise clients on federal, state, and international tax matters and prepare income and other tax returns for millions of Americans. Our members provide services to individuals, not-for-profit organizations, small and medium-sized businesses, as well as America's largest businesses.
We appreciate your consideration of these comments and welcome the opportunity to discuss them further. If you have any questions, please contact Anne Bushman, Chair, AICPA Employee Benefits Taxation Technical Resource Panel, at (202) 370-8213, or anne.bushman@rsmus.com; Kristin Esposito, AICPA Director - Tax Policy & Advocacy, at (202) 434-9241, or kristin.esposito@aicpa-cima.com; or me at (610) 217-4495 or CheriFreeh@gmail.com.
Sincerely,
Cheri Freeh, CPA, CGMA
Chair, AICPA Tax Executive Committee
1/ P.L. 117-328.
2/ Unless otherwise indicated, hereinafter, all section references are to the Internal Revenue Code of 1986, as amended, or to the Treasury Regulations promulgated thereunder.
3/ Proposed Reg. Sec. 1.414(v)-2(d), Example 4.
* * *
Original text here: https://www.aicpa-cima.com/news/article/aicpa-requests-guidance-on-secure-2-0-roth-mandated-catch-up-contributions
[Category: Accounting]
