The Internal Revenue Service recently issued Revenue Procedure 2018-52 (the 2018 RP) to provide revised procedures for its Employee Plans Compliance Resolution System (EPCRS) — the system through which plan sponsors can...more
In Announcement 2015-19 (Announcement), the Internal Revenue Service (IRS) has indicated that it is eliminating the staggered five-year determination letter (DL) remedial amendment cycles for individually designed...more
In a Chief Counsel Memorandum issued last month, the IRS concluded that an executive retention arrangement violated Section 409A despite the employer’s efforts to correct the arrangement before the retention bonus vested....more
The final Section 162(m) regulations issued by the IRS last week have a small but welcome surprise for companies that have recently become public....more