News & Analysis as of

Voluntary Correction Program

403(b) Document Compliance and the Commencement of the Three Year Remedial Amendment Period

by Hodgson Russ LLP on

Unlike profit sharing and 401(k) retirement plans, 403(b) retirement plans only became subject to IRS regulations requiring written plan documents in 2007. Compliance with the written document requirement was made difficult...more

Changes To VCP User Fees: A Holiday Gift That Some Plan Sponsors Would Rather Return

by Jackson Lewis P.C. on

Benefit plan practitioners returned to their desks after the holidays to the surprising news that the Internal Revenue Service issued guidance that made sweeping changes to the user fees for the Internal Revenue Service’s...more

IRS Updates VCP User Fees

The IRS has revised its user fees for the Voluntary Correction Program (VCP) effective for submissions made on or after January 2, 2018. VCP is an IRS program that allows plan sponsors to correct failures involving a...more

New VCP Compliance Fees Will Increase the Cost of Correcting Some of the Most Common Plan Errors

by McDermott Will & Emery on

Last month, the Internal Revenue Service (IRS) published Revenue Procedure 2018-4, which modified the user fee schedule for submissions under the IRS’s Voluntary Correction Program (VCP)....more

IRS Announces Changes to Voluntary Correction Program Fees

by McGuireWoods LLP on

This month, the Internal Revenue Service announced changes to the user fee structure for most voluntary correction program (VCP) submissions under its Employee Plans Compliance Resolution System (EPCRS). Previously, such fees...more

Annual IRS Revenue Procedure Includes Surprising Change to User Fees

On January 2, 2018, the IRS published its annual bulletin that updates procedures for requesting rulings, determinations, and other guidance from the IRS. As in past years, the bulletin includes new user fees for...more

The easiest mistake most 401(k) plan sponsors make

by Ary Rosenbaum on

The road to hell is paved with good intentions and that’s how I feel when it comes sometimes to what a 401(k) plan sponsor does. Yet, there is an error that too many 401(k) plan sponsors do that the Department of Labor (DOL)...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

The ERISA Litigation Newsletter - October 2016

by Proskauer Rose LLP on

Editor's Overview - This month, we look at the implications of the two federal district court cases from California that applied the ban on discretionary clauses typically found in ERISA plans to self-insured plans. 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

April 30 Deadline to Restate Pre-Approved Plans

Sponsors of pre-approved defined contribution retirement plans are generally required to sign new plan documents that incorporate changes required by the Pension Protection Act on or before April 30, 2016. Defined...more

IRS Provides Guidance on New Form 5500 Compliance Questions

by McGuireWoods LLP on

The Internal Revenue Service (IRS) has provided clarification regarding new “compliance questions,” principally for retirement plans, that appear on the 2015 Forms 5500 and 5500-SF. These questions should not be answered....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

Changes to User Fees for Voluntary Correction Program (VCP) Submissions

by Bryan Cave on

On January 4, 2016, the Internal Revenue Service published its annual update of user fees Rev. Proc. 2016-8 for various letter ruling and determination letter requests. The 2016 update now includes user fees and guidance for...more

IRS Reduces VCP User Fees Effective February 2016

On January 4, 2016, the IRS issued Revenue Procedure 2016-8, which provides guidance for complying with the user fee program of the Voluntary Correction Program (VCP). Effective February 1, 2016, the fees for a VCP filing for...more

IRS Updates Guide to Auditing Nonqualified Deferred Compensation Plans

The Internal Revenue Service (IRS) recently updated its “Nonqualified Deferred Compensation Audit Techniques Guide.” The Guide provides a framework for the IRS to audit nonqualified deferred compensation (NQDC) plans. Since...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

Easier, Less Costly Alternatives for Correcting Retirement Plan Mistakes

In two recent Revenue Procedures, the Internal Revenue Service (IRS) has modified the Employee Plans Compliance Resolution System (EPCRS), the IRS correction program for retirement plans. Revenue Procedure. 2015-27 reduces...more

“Voluntary” ? “Obligatory”: Good Deeds Do Not Trigger Coverage

by Carlton Fields on

Liability policies typically provide coverage for amounts the insured “become[s] legally obligated to pay”—but they leave open the question of how that obligation should be determined. Judgments and settlements clearly...more

Employee Plans Compliance Resolution System – Q&A #2

by King & Spalding on

If an employer unintentionally fails to comply with the qualification requirements of the Internal Revenue Code with respect to its qualified plan, the employer may be able to avoid disqualification of the retirement plan if...more

Is There An Elephant In The Room?

by Fisher Phillips on

401(k) Plan documents can read like Russian novels. They are often long and difficult to understand, so it’s no surprise that administrative errors in operating such plans happen frequently. Common errors include omitting or...more

Monthly Benefits Update - November 2013

by Franczek Radelet P.C. on

Health & Welfare Plans - Health Care Reform: Supreme Court Grants Review to Two Cases Challenging ACA’s Contraception Coverage Mandate - The United States Supreme Court has agreed to hear two cases challenging...more

IRS Limited 50% OFF SALE for 403(b) Plans!

by King & Spalding on

Tax exempt employers who sponsor 403(b) plans were generally required to adopt a written plan document by December 31, 2009. If a written document was not timely adopted, the employer may take advantage of the IRS Voluntary...more

IRS to Begin Compliance Checks of Non-Governmental Section 457(b) Plans

by McDermott Will & Emery on

The Internal Revenue Service recently announced it was conducting “compliance checks” of Section 457(b) plans. This newsletter discusses what those compliance checks involve as well as the steps Section 457(b) plan sponsors...more

IRS Issues 403(b) Plan Fix-It Guide

by McDermott Will & Emery on

On February 21, 2013, the Internal Revenue Service (IRS) added to its “self-help” resources a new “403(b) Plan Fix-It Guide” to provide guidance more specifically directed at 403(b) plan sponsors that identify qualification...more

32 Results
|
View per page
Page: of 2
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.