In September, the IRS issued Rev. Proc. 2018-52 updating the IRS
correction program, i.e., Employee Plans Compliance Resolution
System ("EPCRS"). EPCRS allows retirement plan sponsors
to correct compliance failures that may adversely affect the
tax-qualified status of a plan. The primary purpose of the new
Revenue Procedure is to update how plan sponsors may submit
Voluntary Correction Program ("VCP") applications to the
IRS.
Effective April 1, 2019, the IRS will no longer accept paper VCP
submissions or paper check user fee payments. Specifically, the
updated procedures mandate plan sponsors (or their authorized
representatives) to use the www.pay.gov website to file VCP submissions and
to pay applicable user fees. The guidance provides for a transition
period from January 1, 2019, through March 31, 2019, during which
plan sponsors may elect to submit VCP submissions either through
the website or by paper.
