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IRS Confirms: “Insignificance” Still Matters Under EPCRS After Secure 2.0

IRS Notice 2023-43 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 that while the old deadlines for “significant” errors no longer apply, whether a failure is “significant” or “insignificant” does still matter for purposes of determining which errors may be self-corrected when discovered in an examination.

The Notice provides as follows:

Q-5. Before Rev. Proc. 2021-30 is updated pursuant to section 305(g) of the SECURE 2.0 Act, may a plan sponsor self-correct a failure (including an Eligible Inadvertent Failure) that is insignificant, determined in accordance with the factors set forth in section 8.02 of Rev. Proc. 2021-30, even if the plan or plan sponsor is under examination, as defined in section 5.08 of Rev. Proc. 2021-30, and even if the failure is discovered on examination?

A-5. Yes.

We will be covering these issues and more on our webinar Hot off the Press: Applying the IRS's New EPCRS Guidance in the Real World. Join Sherrie Boutwell and Katrina Veldkamp on Thursday, June 15, 2023, from 10am - 10:30am PT. Click below to register.


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