The IRS' Employee plans compliance resolution system (EPCRS) is modified by Revenue procedure 2015-27

Tip of the day

By Stephanie Reagan

sreagan@sunlin.biz

The IRS'  Employee Plans Compliance Resolution System (EPCRS) issued on February 11, 2015 Rev. Proc. 2015-27 which modifies but does not supersede Rev. Proc. 2013-12. This Rev. Proc. 2015-27 is generally effective July 1, 2015 and its use is optional on or after March 27, 2015.

In general, the miscellaneous changes include the following:

  • Reduces certain compliance resolution user VCP fees.

  • A plan may use correction methods other than the correction methods set forth in sections 6.06(3) and 6.06(4) of Rev. Proc. 2013-12.

  • Discusses the challenges of requesting overpayments from participants and allows for flexibility in correcting overpayments.

  • Requests comments on the resolution of the recoupment of plan overpayments.

  • Removes Appendices C & D of Rev. Proc. 2013-12 for the optional Model Compliance Statements. Now an applicant may submit a Model Compliance Statement on Form 14568, Appendix C Part I and if appropriate, one or more schedules, Forms 14568-A through 14568-I.

  •  Generally extends period to correct excess annual additions from 2 1/2 months to 9 1/2 months.

  • Corrects locating lost participant language to include but are not limited to, a mailing to the individual’s last known address using certified mail and, if that is unsuccessful, an additional search method, such as the use of a commercial locator service, a credit reporting agency, or Internet search tools. - this coincides with FAB 2014-01. See our post on Missing Participants dated 2/11/2015 for more information.

  • Clarifies the determination letter application process for corrective amendments.

 

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