[co-author: Kim Lee]
The American Rescue Plan Act of 2021 (“ARPA”), which was signed into law on March 11, 2021, includes a number of provisions relating to health and welfare plans that will be beneficial to many Americans. In addition, ARPA provides funding relief to single-employer defined benefit plans and significant financial assistance to the most underfunded multiemployer plans. However, ARPA does not rescue everyone, and actually expands the group of employees subject to the $1 million dollar limit on certain compensation deductions contained in Section 162(m) of the Internal Revenue Code (“Code”).
ARPA is not the first legislation passed in the wake of the COVID-19 crisis to contain significant benefits- and compensation-related components. For example, the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”) contained a number of benefits and compensation provisions, which were discussed in our March 2020 OnPoint regarding the CARES Act and our Apr