News & Analysis as of

Employee Plans Compliance Resolution System Retirement Plan

403(b) Remedial Amendment Deadline Finally Set

by Seyfarth Shaw LLP on

On January 13, 2017, the IRS issued guidance setting March 31, 2020 as the last day of the remedial amendment period for 403(b) retirement plans. A remedial amendment period is a time frame during which an employer can...more

We Have A Mistake In Our Retirement Plan - What Do We Do?

by Kiesewetter Law Firm on

Plan Sponsors often make mistakes, many of which are inadvertent, regarding employees’ defined benefits and contribution plans. Once the Internal Revenue Service (“IRS”) discovers these mistakes, it could audit the plan...more

Remedial Amendment Period for 403(b) Plans

In Revenue Procedure 2017-8, the IRS announced that the remedial amendment period (“RAP”) for 403(b) plans would end on March 31, 2020. A RAP is a period in which a plan can be amended retroactively to comply with the...more

Are Individually Designed Retirement Plans Destined to Become Dinosaurs?

by Sherman & Howard L.L.C. on

The Impact of Changes to the IRS Determination Letter Program - This January 2017 will see the last regular IRS determination letter applications filed for individually designed retirement plans. After this final Cycle A...more

Employee Benefits Developments - November 2016

by Hodgson Russ LLP on

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of November, 2016. ACA Information Reporting – Bad News and Good News - First, the bad news: The 2016 final...more

ERISA Basics National Institute: Section 401(k) Plans

by McDermott Will & Emery on

A 401(k) plan has a qualified cash or deferred arrangement that is part of a profit sharing plan or stock bonus plan. Under the Internal Revenue Code Section 401(k)(2), an employee may elect to make contributions to the plan,...more

IRS Restates EPCRS Correction Methods and Procedures

by McDermott Will & Emery on

The Internal Revenue Service recently issued Revenue Procedure 2016-51, a new version of the Employee Plans Compliance Resolution System (EPCRS) to consolidate and update its prior guidance regarding how to correct of errors...more

The IRS Voluntary Compliance Program Is Like Your Parents

by Ary Rosenbaum on

As a child, you’re usually told by your parents that they just want to hear the truth and that telling the truth is going to carry a far less punishment than if you lie and try to hide whatever bad thing you do. The...more

IRS Overhauls the Retirement Plan Correction Program

by Bryan Cave on

With the looming end of the determination letter program as we know it, the IRS has issued an updated Revenue Procedure for the Employee Plans Compliance Resolutions System (EPCRS). Released on September 29, 2016, Rev. Proc....more

Maintaining Retirement Plan Documents after Revenue Procedure 2016-37

by McDermott Will & Emery on

At the 2016 Joint Fall CLE Meeting on October 1, 2016, Andrew Liazos presented on “Maintaining Retirement Plan Documents after Revenue Procedure 2016-37.” As an employer sponsoring a retirement plan, you are required by...more

IRS Updates Correction Program for Retirement Plans

by McGuireWoods LLP on

The IRS recently issued Revenue Procedure 2016-51 (the 2016 RP) to provide revised procedures for its Employee Plans Compliance Resolution System (EPCRS) – the system through which plan sponsors can correct errors in the form...more

Compensation and Benefits Insights – September 2016

by King & Spalding on

New Guidance Affects Wellness Program Design - Over the last several months, the Equal Employment Opportunity Commission (“EEOC”) and the Internal Revenue Service (“IRS”) have provided additional guidance regarding the...more

IRS Lays Out Plan for Maintaining Tax Qualification for Individually-Designed Plans after Elimination of the Determination Letter...

by Reed Smith on

On June 29, 2016, the Internal Revenue Service (IRS) released Revenue Procedure 2016-37, which modifies the Determination Letter Program for tax-qualified plans and the requirements for when plan amendments must be adopted by...more

IRS Announces Reduced VCP Compliance Fees

by McDermott Will & Emery on

The Internal Revenue Service (IRS) has announced new general compliance fees for voluntary correction program (VCP) submissions under the Employee Plans Compliance Resolution System (EPCRS), effective February 1, 2016. EPCRS...more

Department of Treasury Issues 2015-2016 Priority Planning Guide

by Franczek Radelet P.C. on

The Department of the Treasury issued its 2015-2016 Priority Guidance Plan detailing projects that it intends on dedicating resources to in the coming year. There are numerous employee benefits-related items in the plan....more

Employee Benefits Alert - July 2015

by Franczek Radelet P.C. on

Major Revisions to Qualified Plan Determination Letter Process Announced - Effective January 1, 2017, the staggered five-year determination letter remedial amendment cycles for individually designed plans will be...more

IRS Overhauls Determination Letter Process for Individually Designed Plans

by Reed Smith on

On July 21, 2015, the Internal Revenue Service (“IRS”) released Announcement 2015-19, which significantly limits the circumstances under which the IRS will accept determination letter applications for individually designed...more

IRS Updates Retirement Plan Correction Procedure (Part 2)

The IRS has provided significant administrative and monetary relief for plans correcting errors involving employee contributions. The changes to the IRS’s Employee Plans Compliance Resolutions System (EPCRS) are set forth in...more

IRS Provides Helpful Updates to Retirement Plan Correction Program

by Reed Smith on

The IRS has issued Revenue Procedures 2015-27 and 2015-28 (“Rev. Proc. 2015-27” and “Rev. Proc. 2015-28”), which modify the IRS’ retirement plan correction programs known as the Employee Plans Compliance Resolution System...more

IRS Updates EPCRS Correction Methods and Procedures

by McDermott Will & Emery on

Reflecting comments it requested, and others it received, the Internal Revenue Service (IRS) recently issued two updates which modify the Employee Plans Compliance Resolution System (EPCRS), which is the comprehensive system...more

IRS Continues to Expand, Encourage and Simplify Correction Program in 2015 Updates to EPCRS

In spite of a plan sponsor's best efforts, errors and failures in administering a retirement plan occasionally come to light. We hear about these errors and failures usually following a change in administration, service...more

More and Less Expensive Options for Retirement Plan Corrections: New IRS Guidance on EPCRS

by Polsinelli on

In This Issue: - Rev. Proc. 2015-27 - Rev. Proc. 2015-28 - For More Information - Excerpt from Rev. Proc. 2015-27: Rev. Proc. 2015-27 may be used beginning March 27, 2015 and is effective July 1,...more

Time Sensitive Updates for Employer-Sponsored Retirement Plans

by Akerman LLP on

There are two time sensitive updates affecting employer sponsored retirement plans that companies should be aware of and review to determine whether action is needed. The first update applies to employers that sponsor a...more

Correcting Problems With Your Retirement Plan

by Smith Anderson on

Presented by Caryn McNeill, Craig Wheaton and Jamie Hinkle The rules that apply to qualified retirement plans are complex. Not surprisingly, plan sponsors determine with some regularity that their plans have a compliance...more

Employee Benefits Developments - April 2015

by Hodgson Russ LLP on

Health Insurance Company’s HIPAA Breach Affects Millions. At the end of January, a national BlueCross BlueShield affiliate, Anthem, Inc., discovered that its information technology systems were hacked. The information...more

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