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ARTICLE · 01 NOVEMBER 2016

IRS Restates EPCRS Correction Methods And Procedures

McDermott Will & Emery
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The Internal Revenue Service recently issued Revenue Procedure 2016-51, a new version of the EPCRS to consolidate and update its prior guidance regarding how to correct of errors in qualified retirement plans.

United StatesEmployment and HR
Joseph Adams
Joseph Adams
Angela Stockbridge
Angela Stockbridge
Susan Peters Schaefer
Susan Peters Schaefer
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The Internal Revenue Service (IRS) recently issued Revenue Procedure 2016-51, a new version of the Employee Plans Compliance Resolution System (EPCRS) to consolidate and update its comprehensive system for correction of retirement plan failures. The full revision of the EPCRS guidance comes as a welcome relief in contrast to the guidance that, until now, had been divided between Revenue Procedure 2013-12, Revenue Procedure 2015-27 and Revenue Procedure 2015-28. The prior guidance also contained outdated references to the IRS's determination letter program, and old model forms for Voluntary Compliance Program (VCP) submissions. Revenue Procedure 2016-51 also makes changes to the user fees and sanctions and clarifies the significance of compliance statements issued after a VCP or Audit Closing Agreement Program (CAP). These changes are effective January 1, 2017. 

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