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IRS Issues Highly Anticipated Update to Qualified Plan Correction Procedures

On July 16, 2021, the IRS issued Revenue Procedure 2021-30, updating its Employee Plans Compliance Resolution System (“EPCRS”), which permits retirement plan sponsors and administrators to correct compliance failures that may...more

Lights, Camera, Action! Another Extension to the Relief For Remote Plan Elections: Is Permanent Relief On Its Way?

Seyfarth Synopsis: The IRS has extended its relief from the physical presence requirement related to certain plan elections through June 30, 2022....more

How to Sign Your Life Away… Electronically

Seyfarth Synopsis: Electronic signatures may be the wave of the future for the IRS, and are more necessary now as a result of the remote work environment. The IRS issued some recent guidance, allowing two authorization forms...more

How to SECURE Your Safe Harbor Plan

Seyfarth Synopsis: The IRS issued Notice 2020-86, which provides guidance on the rules that apply to safe harbor plans that were changed by the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE...more

Happy New Year! The IRS Grants Permission to Celebrate New Year’s Eve

Seyfarth Synopsis: The IRS has announced that the due date for contributions to a single-employer defined benefit pension plan due in 2020, previously extended to January 1, 2021 by the CARES Act, will be considered timely if...more

IRS Provides Additional Clarity on Key SECURE Act Provisions

On December 20th, before the outbreak of COVID-19 and the resulting pandemic, President Trump signed into law the Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”) and the Bipartisan...more

Hybrid Plan Filing Reprieve…. Sort of

Seyfarth Synopsis: The IRS published guidance in its Employee Plans newsletter on August 24, 2020, allowing incomplete determination letter applications to be filed by August 31, 2020, with an opportunity to supplement the...more

The IRS Speaks: Coronavirus Distributions From Retirement Plans

Seyfarth Synopsis: The IRS has issued some initial guidance on the coronavirus-related relief for retirement plans (and IRAs) under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) in the form of Q&As on...more

The IRS Speaks: Retirement Plan Coronavirus Loan Relief

Seyfarth Synopsis: The IRS has issued some initial guidance on the coronavirus-related relief for retirement plans (and IRAs) under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) in the form of Q&As on...more

IRS Repurposes Military and Disaster Relief For COVID-19 Deadline Extensions

Seyfarth Synopsis: On April 9, 2020, the IRS issued Notice 2020-23, extending federal tax filing deadlines and payment obligations to July 15, 2020 for certain items otherwise due to be performed from April 1, 2020 through...more

Whistleblowing Hits Employee Benefits World

Seyfarth Synopsis: Recently a “whistleblower” leaked that the IRS had internally announced an upcoming modification to the very popular voluntary correction program (“VCP”) that would have been a significant disincentive for...more

Qualified Plan Uncashed Check Guidance Issued Related to Tax Obligations

On August 14, 2019, the IRS issued Revenue Ruling 2019-19, providing guidance to both tax-qualified plan administrators and participants on the tax treatment of plan distribution checks that are not cashed. ...more

IRS Issues Update To Qualified Plan Correction Guidance

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...more

Newly Proposed IRS Rules Permit the Use of Forfeitures for QNECs and QMACs

On January 18, 2017, the IRS issued proposed regulations that expand the permitted uses of forfeitures in a 401(k) plan. Under the proposed rules, the definitions of “qualified nonelective contributions” (QNECs) and...more

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