The View from Proskauer on Developments in the World of Employee Benefits, Executive Compensation & ERISA Litigation
The IRS recently updated its “Employee Plans Compliance Resolution System” (EPCRS). By way of background, EPCRS is a correction program administered by the IRS for plan sponsors to correct certain retirement plan errors. EPCRS is comprised of three different components: the Self-Correction Program, the Voluntary Correction Program, and the Audit Closing Agreement Program.
The updated…
On May 1, 2019, the IRS released Revenue Procedure 2019-20 which provides for a limited-scope expansion of its determination letter program for individually designed plans. Beginning on September 1, 2019, the IRS will accept determination letter applications submitted for the following types of plans:
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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 determination requests and submissions under the Voluntary Correction Program (“VCP”). But this year’s update includes a significant surprise for the VCP…
On September 29, 2016, the IRS released new guidelines under its Employee Plans Compliance Resolution System (EPCRS). EPCRS consists of three programs by which plan sponsors can correct plan documentation or operational errors – the Self-Correction Program, the Voluntary Correction Program and the Audit Closing Agreement Program. Rev. Proc. 2016-51 supersedes the older guidelines (Rev.…
Less than a week after issuing significant modifications to the Employee Plans Compliance Resolution System (EPCRS) (as described in our March 31, 2015 blog), the Internal Revenue Service (IRS) further modified EPCRS through the release of Revenue Procedure 2015-28. The new guidance provides welcome relief (provided certain requirements are met) from the current standard (or safe harbor) EPCRS correction method for elective deferral failures, which has been widely viewed as providing affected participants with a windfall. Also, in an effort to facilitate the adoption of automatic contribution arrangements and prompt correction of failures, the IRS has established favorable safe harbor correction methods for elective deferral failures.
On March 27, 2015, the Internal Revenue Service (IRS) released Revenue Procedure 2015-27, which modifies, effective July 1, 2015, prior guidelines under the Employee Plans Compliance Resolution System (EPCRS). The IRS established EPCRS so that plan sponsors could correct documentary and operational errors without jeopardizing a plan’s tax qualified status. EPCRS consists of three programs under which plan sponsors can correct plan errors – the Self-Correction Program, the Voluntary Correction Program and the Audit Closing Agreement Program. The new guidance modifies, but does not supersede, the most recent restatement of EPCRS set forth in Revenue Procedure 2013-12.
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