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02Mar

FLASHPOINT: IRS REPRESENTATIVES SAY NO IMMINENT VCP CHANGES

IRS representatives attending the TE/GE Council meetings this week have confirmed that there is no significant action being taken by the IRS at this time to modify the Voluntary Correction Program (VCP) program. On February 25, 2020, the American Retirement Association (ARA) reported in its online newsletters that, according to an IRS whistleblower, the IRS […]
23Apr

FLASHPOINT: CORRECTIONS MADE EASIER: THE IRS EXPANDS THE SELF-CORRECTION PROGRAM

Last year, the IRS modified its correction programs for qualification failures (the “Employee Plans Compliance Resolution System” or “EPCRS”) to significantly increase the fees for taking part in the Voluntary Compliance Program (“VCP”). (See our previous FlashPoint on this subject.) Since that occurred, the retirement plan community has responded with demands that the IRS expand its […]
03Oct

FlashPoint: New EPCRS Procedure: Electronic Submission of VCP and Not A Whole Lot More

On September 28, 2018, the IRS issued Revenue Procedure 2018-52, the latest version of the Employee Plans Compliance Resolution System (“EPCRS”), the IRS’s comprehensive procedures for correcting retirement plan errors. Using this procedure, retirement plan sponsors may fix mistakes in their qualified plans, 403(b) plans, 403(a) retirement annuities, SEPs, and SIMPLEs. Although they are not […]
08Jan

FLASHPOINT: STICKING IT TO THE LITTLE MAN: WHY THE NEW IRS VCP FEES ARE BAD FOR SMALL BUSINESS, TPAS, AND RETIREMENT PLANS

  Forgive us if we don’t sing the praises of the Internal Revenue Service (“IRS”) for the most recent update to the Voluntary Correction Program (“VCP”) fee schedule.  A number of articles have been published since the release of Revenue Procedure (“Rev. Proc.”) 2018-4, expressing enthusiasm about the reduction of the fees for mega-corporations that […]