IRS modifies Employee Plans Compliance Resolution System

Tax Hot TopicsTax Hot Topics In Rev. Proc. 2015-27, the IRS modified portions of the Employee Plans Compliance Resolution System (EPCRS). The IRS also released a chart including the significant modifications to the EPCRS.

The recently released revenue procedure modifies Rev. Proc. 2013-12, which was issued in 2013 to provide guidance regarding the voluntary correction program for employee retirement plans, referred to as the EPCRS. Under EPCRS, plan sponsors can correct certain errors in retirement plans, in some cases without having to notify the IRS. The correction programs under EPCRS include the Self-Correction Program (SCP), the Voluntary Correction Program (VCP) and the Audit Closing Agreement Program (Audit CAP).

The most recent modifications include the following highlights:
  • A clarification of correction rules for overpayments made to participants
  • A modification to SCP for Section 415(c) failures
  • Lower compliance fees for certain VCP submissions
  • A new acknowledgment letter form and other VCP model document changes

Rev. Proc. 2015-27 is generally effective July 1, 2015. However, plan sponsors are permitted to apply the revenue procedure on or after March 27, 2015.

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