Tag Archives: Employee Plans Compliance Resolution System (EPCRS)

IRS Overhauls the Retirement Plan Correction Program

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. 2016-51 updates the EPCRS […]

Posted in Legal Updates, Plan Administration and Compliance, Qualified Plans, Tax-qualified Retirement Plans | Tagged , , , , | Leave a comment

Do You Know Where Your Participants Are?

The Department of Labor (“DOL”) has recently implemented an initiative to investigate the manner in which defined benefit plans of large employers comply with the required minimum distribution rules set forth in Section 401(a)(9) of the Internal Revenue Code (“Code”). […]

Posted in Plan Administration and Compliance, Qualified Plans, Tax-qualified Retirement Plans | Tagged , , | Leave a comment

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

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 Voluntary Correction Program (VCP) […]

Posted in Legal Updates, Plan Administration and Compliance, Qualified Plans, Tax-qualified Retirement Plans | Tagged , , , , , , , | Leave a comment

Overpayments to Participants

The IRS has clarified its correction guidance recently to say that errors made in overpaying participants for their benefits can be cured by employer make-up contributions, rather than by pursuing participants and beneficiaries for the overpayments they have received. In […]

Posted in Legal Updates, Plan Administration and Compliance, Qualified Plans, Tax-qualified Retirement Plans | Tagged , , | Leave a comment

IRS issues updates to the Retirement Plan Correction Program

In response to comments from the employee benefits community, the IRS has issued two updates in quick succession for the Employee Plans Compliance Resolution System (EPCRS). The new procedures – Rev. Proc. 2015-27 and Rev. Proc. 2015-28 – do not […]

Posted in Legal Updates, Plan Administration and Compliance, Qualified Plans, Tax-qualified Retirement Plans | Tagged | Leave a comment

Correcting 401(k) Plan Loans Under EPCRS

Participant loans from 401(k) plans must satisfy certain rules under section 72(p) of the Internal Revenue Code (the “Code”) to prevent the loan from being treated as a taxable distribution (sometimes called a “deemed distribution”).  The amount of the loan […]

Posted in Legal Updates, Plan Administration and Compliance, Qualified Plans, Tax-qualified Retirement Plans | Tagged , , , , , , , , | Leave a comment

IRS Updates Retirement Plan Correction Program

After a long wait, an updated Revenue Procedure for the Employee Plans Compliance Resolution System (EPCRS) was released in the form of Rev. Proc. 2013-12.  The new Revenue Procedure makes some important changes to the EPCRS. As many plan sponsors […]

Posted in Governmental Plans, Legal Updates, Plan Administration and Compliance, Tax-qualified Retirement Plans | Tagged , , , , , , , , , , | Leave a comment