Employee Plans Compliance Resolution System

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On February 7, 2024, the IRS announced the second phase of its Pre-Examination Retirement Compliance Program (we discussed phase one in our earlier post here).  Under this program, sponsors will be notified that their plan is selected for examination and will have 90 days to review and correct any plan document or operational errors…

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:

  • Statutory hybrid plans (e.g., cash balance or pension equity plans). Applications

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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…