On May 8, 2023, I wrote how guidance was sorely needed on SECURE 2.0’s self-correction of eligible inadvertent failures. See Guidance Sorely Needed On SECURE 2.0 Self-Correction of Inadvertent Failures. On May 25, the IRS issued Notice 2023-43 (Notice) providing guidance in the form of questions and answers meant to provide taxpayers guidance in

On May 4, the IRS issued Notice 2023-36 inviting the public to submit recommendations for its 2023-2024 Priority Guidance Plan. While the IRS has its hands full due to the over 90 changes to retirement plan law contained in the SECURE 2.0 legislation enacted last December, I believe one particular provision needs guidance as soon

On July 16, 2021, the IRS released its updated Employee Plans Compliance Resolution System (EPCRS) by issuing Rev. Proc. 2021-30 setting forth the parameters of the program and replacing the former governing revenue procedure, Rev. Proc.  2019-19.  EPCRS is a comprehensive system under which employers can save the favorable tax treatment of retirement plans intended

Just a brief post to let you know that I will be presenting a webinar for the Western Pension and Benefits Council Governing Board titled Voluntary Closing Agreements–The Non-EPCRS Correction Program on August 21 at 10 am PST.  I will discuss fixing plan issues that do not qualify for correction under the Employee Plans Correction

This post takes a deeper dive into the expansion of the self-correction program under EPCRS by reproducing my article from this month’s Compensation Planning Journal.  The article discusses the increase in user fees under the Voluntary Correction Program which caused the industry to push back on the cost and request expanded self-correction to ease the

Employers taking advantage of any self-correction should prepare appropriate documentation.

By now you’ve probably read that the IRS has expanded the failures that can be self-corrected under the Employee Plans Compliance Resolution System (EPCRS) as set forth in Rev. Proc. 2019-19 issued April 19, 2019.  This development comes on the heels

In January, the IRS announced changes to the fees required for filing under the Voluntary Correction Program (VCP) of the Employee Plans Compliance Resolution System (EPCRS).  The VCP program allows employers to voluntarily bring errors in plan documentation or operation to the attention of the IRS, and propose a correction method, and receive a compliance