The IRS has now issued Notice 2023-43 which provides interim guidance on its interpretation of the Secure Act 2.0’s changes to the Employee Plans Resolution System. Taxpayers may rely on the guidance until the IRS issues its update to Revenue Procedure 2021-30. The new guidance clarifies the following:
1. When does Secure 2.0 allow self-correction?
2. What types of failures may not be self-corrected?
3. What provisions of Rev. Proc. 2021-30 no longer apply?
4. What is a specific commitment to correct?
5. What is a reasonable period to self-correct?
6. Does self-correction result in a waiver of an otherwise applicable excise tax?
7. What recordkeeping requirements apply?
8. May IRA custodians self-correct before the new revenue procedure is issued?
Be sure to sign up here for updates, as we will be covering the IRS’s position on these questions over the next few weeks.
And, mark your calendars and join Sherrie Boutwell and Katrina Veldkamp as they discuss the new guidance in our webinar: Hot off the Press: Applying the IRS’s New EPCRS Guidance in the Real World, June 15, 2023 from 10am - 10:30am. You can register by clicking the button below.