Practical Law has updated its resources for the new guidance on the Employee Plans Compliance Resolution System (EPCRS).
On September 29, 2016, the IRS issued Revenue Procedure 2016-51, a consolidated statement of the correction programs under the IRS' Employee Plans Compliance Resolution System (EPCRS). Rev. Proc. 2016-51 modifies and supersedes Rev. Proc. 2013-12, which is the prior consolidated statement of EPCRS programs. The updated EPCRS:
Eliminates references to determination letter application requirements in light of Rev. Proc. 2016-37, which changed the determination letter program by terminating the five-year remedial amendment cycles for individually designed qualified plans.
Consolidates previous EPCRS guidance, including:
Rev. Proc. 2015-27;
Rev. Proc. 2015-28; and
Rev. Proc. 2016-8.
Clarifies and provides new guidance on several common correction methods available under EPCRS.