Matching Puerto Rico 401(k) Participants’ School Debt Repayments

U.S. companies that provide matching contributions on qualified student loan payments for employees in retirement plans that are qualified in the United States and Puerto Rico must do so under the same terms and conditions for participants in both jurisdictions. P.R.-only qualified plans may safely provide such QSLP matching contributions by following the relevant rules of I.R.C. §401(m)(4)(D) and (m)(13), their enacting regulations, and IRS administrative guidance on the subject. In either case, the dual- or P.R.-only qualified plan must be amended accordingly, and the corresponding amendment must be filed with the Puerto Rico Department of the Treasury (“Hacienda”) for ...