Need a Do-Over? IRS Expands and Updates Qualified Plans Correction Guidance

By , and on September 8, 2021

The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-30, which provides an updated version of the Employee Plans Compliance Resolution System (EPCRS).

EPCRS is the IRS’s comprehensive program for plan sponsors to correct tax-qualified plan errors. This EPCRS update expands plan sponsors’ ability and methods to correct overpayments and to self-correct certain plan failures without filing a Voluntary Compliance Program (VCP) application, which can be costly and time-consuming. However, the IRS also eliminated the ability of plan sponsors to submit an anonymous VCP application, replacing anonymous VCP submissions with a pre-submission conference option.

Read more here.

AvatarNick Paul
Nick Paul focuses his practice on employee benefits and executive compensation matters for public and private companies. Nick regularly leads due diligence and advises on employee benefits and executive compensation issues in connection with corporate transactions involving both public and private companies. Nick also regularly drafts and advises on issues related to cash bonus plans, equity compensation plans, phantom unit plans, executive severance and change in control agreements and executive employment agreements. Read Nick Paul's full bio.


Jeffrey HoldvogtJeffrey Holdvogt
Jeffrey (Jeff) M. Holdvogt advises clients regarding a wide range of employee benefits matters. He focuses primarily on the design and administration of complex pension, defined contribution and executive deferred compensation arrangements. Jeff counsels privately and publicly held corporations on ongoing day-to-day retirement and executive compensation issues, as well as employee benefits design and transition matters arising from corporate mergers, acquisitions and divestitures. Read Jeff Holdvogt's full bio.


Diane MorgenthalerDiane Morgenthaler
Diane M. Morgenthaler focuses her practice on employee benefits and executive compensation. She represents clients in matters before the US Internal Revenue Service, the Department of Labor and the Pension Benefit Guaranty Corporation. Diane serves as employee benefit counsel to Fortune 500 corporations and other global corporations, and represents both public and private clients. She regularly designs and implements a variety of employee benefit plans and programs. Diane has extensive experience in employee benefit issues involved in acquisitions, reorganizations and divestitures and in the design of employee benefits plans following such transactions. She also advises clients in matters involving multi-employer withdrawal liability, fiduciary liability and benefit claims. Read Diane Morgenthaler's full bio.

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