News & Analysis as of

Internal Revenue Code (IRC) Overpayment Benefit Plan Sponsors

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

Bricker Graydon LLP on

Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...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

Foley & Lardner LLP

Some Welcome News: IRS Expands and Modifies Its Correction Methodology with New Employee Plans Compliance Resolution System...

Foley & Lardner LLP on

Plan sponsors and other administrators of eligible retirement plans must ensure that these plans are operated properly in accordance with the applicable requirements of the Internal Revenue Code, including the applicable plan...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

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