October 18, 2016
On September 29, 2016, the Internal Revenue Service (IRS) released Revenue Procedure 2016-51, an update of its correction programs for pension plans, the Employee Plans Compliance Resolution System (EPCRS). The new Revenue Procedure consolidates and replaces prior revenue procedures describing the correction program (Rev. Procs. 2013-12, 2015-27 and 2015-28).
The key changes, as summarized on the IRS EPCRS webpage, include:
Revenue Procedure 2016-51 is effective January 1, 2017. Despite the final nature of the Revenue Procedure, the IRS is inviting comments generally, and specifically continues to ask for comments related to the recoupment of overpayments. No deadline for comments is specified.