Ronald Cluett Comments on Employee Plans Compliance Resolution System in Tax Notes
The anticipated IRS guidance on a plethora of SECURE 2.0 provisions enacted at the end of 2022 has still not arrived as the calendar year turns to the second half of 2024.
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The approaching deadline for changes to the Employee Plans Compliance Resolution System to align with the provisions of SECURE 2.0 is drawing attention.
Ronald G. Cluett of Caplin & Drysdale said the interim guidance (Notice 2023-43, 2023-24 IRB 919) on the expanded use of self-correction to address failures was “welcome and helpful.” But he added that it didn’t satisfy SECURE 2.0’s requirement to revise the Employee Plans Compliance Resolution System under Rev. Proc. 2021–30, 2021-31 IRB 172, which must be done within two years of the law’s enactment.
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