News & Analysis as of

Retirement Plan Employee Benefits Revenue Procedures

Bradley Arant Boult Cummings LLP

Every Retirement Plan Needs Practices and Procedures for Self-Correction

Administering a retirement plan is a complicated task fraught with potential missteps. Fortunately, employers are now able to self-correct most errors and thereby avoid the considerable time and expense of filing an...more

Holland & Hart - The Benefits Dial

You Live, You Learn… Correcting “Qualification Failures” under the Self-Correction Program

The Employee Plans Compliance Resolution System (“EPCRS”), as set forth in Revenue Procedure 2021-30, allows plan sponsors to correct “Qualification Failures,” which are defined as any plan document, operational, demographic...more

Verrill

Establishing Practices and Procedures to Support Self-Correction of Operational Failures

Verrill on

The self-correction of retirement plan operational failures under IRS correction principles has been conditioned upon a plan sponsor’s establishment of compliance practices and procedures since the creation of the Employee...more

Miller Canfield

Individually Designed 403(b) Plans will be Eligible for Determination Letters

Miller Canfield on

​​​​​​​Plan sponsors of individually designed 403(b) plans will soon be able to submit determination letter applications to the IRS. (Individually designed plans are plans using custom documents that have not been preapproved...more

BCLP

Alert: New IRS Retirement Plan Compliance Program

BCLP on

Dear Plan Sponsor - Have you received a letter from the IRS with respect to your retirement plan? If so (or if not, but you want to be prepared in the event you do receive “the letter”), read on....more

Faegre Drinker Biddle & Reath LLP

IRS Pilots Pre-Examination Compliance Program for Retirement Plans

In its recent June Employee Plans newsletter, the Internal Revenue Service (IRS) announced the launch of a 90-day pre-examination compliance pilot program. Under the program, the IRS will notify a plan sponsor that its...more

Laner Muchin, Ltd.

Plan Administrators of Retirement Plans Need to Prepare for New IRS Pre-Examination Compliance Pilot Program

Laner Muchin, Ltd. on

On June 3, 2022, the Internal Revenue Service (IRS) announced a new pilot program aimed at qualified retirement plan compliance. Pursuant to the program, the IRS will issue a letter to the plan administrator which provides a...more

McDermott Will & Emery

New IRS Pre-Audit Compliance Program for Retirement Plans

McDermott Will & Emery on

Retirement plan sponsors should be aware of a new Internal Revenue Service (IRS) pilot program, which permits plan sponsors to conduct a pre-examination “check-up” of retirement plan administration before the IRS begins a...more

Holland & Knight LLP

IRS Announces Retirement Plan Compliance Pilot Program

Holland & Knight LLP on

Under the IRS Employee Plans Compliance Resolution System (EPCRS), as set forth in Revenue Procedure 2021-30, a plan that has been notified of an impending audit cannot remedy issues using the Voluntary Correction Program,...more

Snell & Wilmer

New Ways to Self-Correct Overpayments Under EPCRS

Snell & Wilmer on

On July 16, 2021, IRS issued Revenue Procedure 2021-30 to update the Employee Plans Compliance Resolutions System (the “EPCRS”). The update in part expands the opportunities for plan sponsors to self-correct failures under...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

IRS updates EPCRS

The IRS has updated the Employee Plans Compliance Resolution System (EPCRS) with the release of Revenue Procedure 2021-30. The EPCRS is used to correct certain plan qualification failures. EPCRS contains the Self-Correction...more

Faegre Drinker Biddle & Reath LLP

Revised IRS Correction Procedures (EPCRS) Include Helpful Changes

On July 16, 2021, the Internal Revenue Service (“IRS”) published an updated version of its correction procedures for qualified retirement plans, Revenue Procedure 2021-30, the Employee Plans Compliance Resolution System...more

McDermott Will & Emery

Need a Do-Over? IRS Expands and Updates Qualified Plans Correction Guidance

McDermott Will & Emery on

The Internal Revenue Service (IRS) issued Revenue Procedure 2021-30, which provides an updated version of the Employee Plans Compliance Resolution System (EPCRS). EPCRS is the IRS’s comprehensive program for plan sponsors to...more

Buchalter

EPCRS Provides More Retirement Plan Self-Correction Opportunities  

Buchalter on

On July 16, 2021 the IRS issued Revenue Procedure 2021-30, which modifies and supersedes Revenue Procedure 2019-19, expanding the Employee Plans Compliance Resolution System (“EPCRS”). EPCRS is a program for correcting...more

Morgan Lewis

Relaxed IRS Self-Correction Rules a Boon for Plan Sponsors—and an Opportunity to Correct Failures Now

Morgan Lewis on

On July 16, 2021, the Internal Revenue Service (IRS) released Revenue Procedure 2021-30, which made several important changes to the Employee Plans Compliance Resolution System (EPCRS) and expanded the ability of plan...more

Eversheds Sutherland (US) LLP

IRS goes for gold with EPCRS Expansion

Just in time for the Olympics, the Internal Revenue Service (IRS) is attempting to take a medal in the category of “long-form voluntary compliance programs”. The IRS issued Revenue Procedure 2021-30 (Rev. Proc. 2021-30),...more

Morgan Lewis

IRS Expands Self-Correction Procedures, but Eliminates Anonymous Voluntary Correction Program

Morgan Lewis on

The Internal Revenue Service (IRS) made important changes to the Employee Plans Compliance Resolution System (EPCRS) in Revenue Procedure 2021-30 that are helpful for plan sponsors as they expand the ability of plan sponsors...more

Stinson LLP

IRS Releases Revised Employee Plans Compliance Resolution System

Stinson LLP on

On Friday, July 16, 2021, the Internal Revenue Service (IRS) published the most recent revision to the Employee Plans Compliance Resolution System (EPCRS) in Revenue Procedure 2021-30. Revenue Procedure 2021-30 supersedes and...more

Seyfarth Shaw LLP

Hybrid Plan Filing Reprieve…. Sort of

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS published guidance in its Employee Plans newsletter on August 24, 2020, allowing incomplete determination letter applications to be filed by August 31, 2020, with an opportunity to supplement the...more

Seyfarth Shaw LLP

Avoid the IRS’s Nuclear Option – Sign that Plan Document!

Seyfarth Shaw LLP on

Seyfarth Synopsis: In a recent Chief Counsel Memorandum (“CCM”), the IRS stated that on audit, agents should pursue plan disqualification for a failure to produce a signed plan document. The IRS was responding to a 2018 Tax...more

Stoel Rives LLP

2020 Health and Welfare Benefit Plan Limits Released by IRS

Stoel Rives LLP on

The IRS issued Revenue Procedure 2019-44 today that provides the 2020 cost-of-living inflation adjustments for certain health and welfare benefit plans. Some of these amounts have been previously released by the IRS. Here are...more

McDermott Will & Emery

Right Around the Corner: Expanded IRS Determination Letter Program Opens in September

McDermott Will & Emery on

Beginning September 1, 2019, the IRS is expanding its retirement plan determination letter program to apply to certain individually designed statutory hybrid and merged plans. Employers sponsoring hybrid plans not previously...more

King & Spalding

Compensation and Benefits Insights – July 2019

King & Spalding on

In May 2019, the IRS issued Revenue Procedure 2019-20, which provides for a limited expansion of the determination letter program for certain individually-designed plans. Under this expansion, the IRS will accept...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

A Welcome Expansion: IRS Resuscitates Determination Letter Program

Beginning September 1, 2019, employers that sponsor cash balance plans and certain merged plans can sleep easier. Revenue Procedure 2019-20, issued by the Internal Revenue Service (IRS) on May 1, 2019, opens the IRS’s...more

King & Spalding

Compensation and Benefits Insights – June 2019

King & Spalding on

On April 19, 2019, the Internal Revenue Service (“IRS”) released Revenue Procedure 2019-19 (the “Revenue Procedure”) and a separate IRS Release (the “Release”) updating the Employee Plans Compliance Resolution System...more

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