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Updated EPCRS and Plan Interim Amendments: New Rules and Coordination Issues

ABA JOINT COMMITTEE ON EMPLOYEE BENEFITS  • DATE: October 7, 2008
SPONSORS: The Sections of Business Law, Health Law, Labor and Employment Law, Real Property, Trust and Estate Law, Taxation, and Tort Trial and Insurance Practice; And the American College of Employee Benefits Counsel

General Information

A 90-minute TeleConference/Live Audio Webcast
Tuesday, October 7, 2008
1:00-2:30 pm ET / 12:00-1:30 pm CT / 11:00 am-12:30 pm MT / 10:00 am-11:30 am PT


Government representatives and practitioners will review the recent changes to the Employee Plans Compliance Resolution System (EPCRS) revenue procedure (Revenue Procedure 2008-50) and discuss current retirement plan required and discretionary interim amendment rules. The coordination between interim amendment requirements and the EPCRS correction process when interim amendments are not properly adopted will be discussed. Some of the topics that will be discussed include:
  • Expanded Self-Correction Program (SCP)
  • Current required and discretionary interim amendment rules
  • Streamlined Voluntary Correction Program (VCP) Application Procedures
  • Definition of a discretionary amendment and due date of such amendment
  • Correction of Plan loan failures
  • De Minimis contribution / distribution failures
  • Correction of interim and certain discretionary nonamender failures

    Moderator: Martha L. Hutzelman, Kruchko & Fries, McLean, VA
    Panelists: Joyce I. Kahn, Manager, Employee Plans Voluntary Compliance, Tax Exempt and Government Entities, Internal Revenue Service, Washington, DC; Thomas R. Pevarnik, Deloitte Tax LLP, Washington, DC; Martin L. Pippins, Manager, Employee Plans Technical Guidance and Quality Assurance, Tax Exempt and Government Entities, Internal Revenue Service, Washington, DC; Lisa A. Tavares, Venable LLP, Washington, DC

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    Updated EPCRS and Plan Interim Amendments: New Rules and Coordination Issues
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