Tuesday, October 23, 2018
Late aftermost month, the IRS appear the latest adaptation of its Employee Affairs Acquiescence Resolution System, the IRS’s affairs for acclimation retirement plan errors. The newest adaptation of the alteration program—effective alpha in 2019—includes mostly accessory changes and clarifications. Most importantly, however, it requires cyberbanking filing of Voluntary Alteration Affairs submissions alpha April 1, 2019.
The Internal Acquirement Account (IRS) afresh issued an updated version of its Employee Affairs Acquiescence Resolution System (EPCRS) ambience alternating changes in how Voluntary Alteration Affairs (VCP) submissions will be filed with the IRS in 2019. Most notably, cyberbanking filing of VCP submissions will be accessible as of January 1, 2019 and will be appropriate as of April 1, 2019. The adapted adaptation of EPCRS does not accommodate any cogent changes to the accepted Self-Correction Affairs (SCP) or the Audit Closing Agreement Affairs (Audit CAP).
EPCRS sets alternating procedures for acclimation errors in retirement plan abstracts and administration. VCP, which is one basic of EPCRS, is frequently acclimated by plan sponsors to access IRS approval for the alteration of plan failures. Historically, VCP filings appropriate the acquiescence of adamantine archetype forms to the IRS via US mail or authentic bagman service, forth with a concrete analysis for the user fee.
In the adapted adaptation of EPCRS, the IRS appear that it is transitioning to cyberbanking acquiescence and acquittal for VCP filings. From January 1 through March 31, 2019, plan sponsors will accept the advantage to book and pay electronically beneath the new adaptation of EPCRS or may book and pay with a adamantine archetype acquiescence beneath the above-mentioned adaptation of EPCRS. Alpha April 1, 2019, all submissions charge be filed electronically in accordance with the afterward new EPCRS procedures:
VCP submissions will be filed electronically through www.pay.gov and will crave the conception of a www.pay.gov account.
The filer will charge to electronically complete Form 8950, Application for VCP Acquiescence beneath EPCRS, through the www.pay.gov website. For all added apparatus of the VCP submission, the filer charge abridge and upload a distinct PDF to the www.pay.gov website. This PDF will be accountable to a 15 MB admeasurement limit. EPCRS provides instructions for alone faxing added abstracts that would aftereffect in the PDF beyond that limit.
The IRS will not affair acceptance belletrist for cyberbanking submissions. Instead, cancellation of a acquiescence will be accustomed through the bearing of a tracking ID issued by www.pay.gov.
A plan sponsor may baptize an accustomed adumbrative to book a VCP acquiescence with the IRS application the www.pay.gov website. A Form 2848 (Power of Attorney) charge be completed in accordance with the specific instructions provided in EPCRS, and the plan sponsor charge abide a amends of canard account advertence that the acquiescence has been advised and, to the best of its knowledge, is complete and accurate.
The adapted adaptation of EPCRS incorporates a few added changes that are constant with above-mentioned advice and of almost bound scope. However, plan sponsors and their assembly should agenda the following:
EPCRS states that if the IRS determines a acquiescence is complete and agrees with the proposed alteration method, a acquiescence account may be issued after the IRS contacting the plan sponsor or its accustomed representative. This has implications for modifying or addition a VCP filing. In the past, plan sponsors about waited until a filing was assigned to an abettor to analyze or supplement it. Going forward, plan sponsors should acquaintance the “VCP Status Inquiry Line” at the cardinal provided in EPCRS if they appetite to adapt or supplement a filing, and the IRS will accommodate added instruction.
The recommended adjustment in which VCP abstracts should be accumulated aural a filing has been updated.
The IRS accepted that changes in VCP fees will abide to be appear through anniversary acquirement procedures issued by the IRS rather than actuality appear anon in EPCRS.
Of appliance to Section 403(b) plan sponsors, the adapted adaptation of EPCRS provides that the aforementioned rules for authoritative antidotal amendments to pre-approved Section 401(a) affairs applies to Section 403(b) plans.
With account to approaching guidance, EPCRS states that the US Department of the Treasury and the IRS are in the action of reviewing comments accompanying to modifying the alteration of overpayments and accretion SCP, and that EPCRS may be adapted to reflect changes in these areas in the future.
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