News & Analysis as of

Revenue Procedures Audits Internal Revenue Service

Eversheds Sutherland (US) LLP

IRS re-commits to pre-filing agreements

On June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Revenue Procedure 2022-39 Continues Qualified Amended Return Treatment for Audit Disclosures, Adds Large Partnership

On November 16, 2022, the IRS released a long-awaited update to the procedure for large corporate taxpayers and large partnerships under continuous audit to obtain Qualified Amended Return (QAR) treatment for items disclosed...more

McDermott Will & Emery

IRS Issues New Procedures for Large Corporate Audit Disclosures

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For decades, large corporate taxpayers under continuous audit have been able to make disclosures under Revenue Procedure 94-69 at the beginning of an examination to notify the Internal Revenue Service (IRS) of adjustments...more

BCLP

Alert: New IRS Retirement Plan Compliance Program

BCLP on

Dear Plan Sponsor - Have you received a letter from the IRS with respect to your retirement plan? If so (or if not, but you want to be prepared in the event you do receive “the letter”), read on....more

Fox Rothschild LLP

Beware of the Exempt Organization Examination: IRS Audits of Charities are Becoming More Common

Fox Rothschild LLP on

As the Internal Revenue Service ramps up its audit staff, its gaze is extending beyond the for-profit sector. IRS audits of public charities are also increasing. We have recently assisted several charities with their...more

Laner Muchin, Ltd.

Plan Administrators of Retirement Plans Need to Prepare for New IRS Pre-Examination Compliance Pilot Program

Laner Muchin, Ltd. on

On June 3, 2022, the Internal Revenue Service (IRS) announced a new pilot program aimed at qualified retirement plan compliance. Pursuant to the program, the IRS will issue a letter to the plan administrator which provides a...more

Holland & Knight LLP

IRS Announces Retirement Plan Compliance Pilot Program

Holland & Knight LLP on

Under the IRS Employee Plans Compliance Resolution System (EPCRS), as set forth in Revenue Procedure 2021-30, a plan that has been notified of an impending audit cannot remedy issues using the Voluntary Correction Program,...more

BCLP

EO Update: e-News for Charities & Nonprofits - September 2021

BCLP on

Updated Procedures Related to Direct Contact in the Determination Process - On August 17, 2021, Exempt Organizations Rulings & Agreements (EO R&A) office issued Interim Guidance (IG) memorandum (TEGE-07-0821-0016) on...more

McDermott Will & Emery

Need a Do-Over? IRS Expands and Updates Qualified Plans Correction Guidance

McDermott Will & Emery on

The Internal Revenue Service (IRS) issued Revenue Procedure 2021-30, which provides an updated version of the Employee Plans Compliance Resolution System (EPCRS). EPCRS is the IRS’s comprehensive program for plan sponsors to...more

Foley & Lardner LLP

Some Welcome News: IRS Expands and Modifies Its Correction Methodology with New Employee Plans Compliance Resolution System...

Foley & Lardner LLP on

Plan sponsors and other administrators of eligible retirement plans must ensure that these plans are operated properly in accordance with the applicable requirements of the Internal Revenue Code, including the applicable plan...more

Eversheds Sutherland (US) LLP

Last minute addition to your summer reading list: Rev. Proc. 2021-34, IRS guidance for implementing the final Section 451...

On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more

Morgan Lewis

IRS Expands Self-Correction Procedures, but Eliminates Anonymous Voluntary Correction Program

Morgan Lewis on

The Internal Revenue Service (IRS) made important changes to the Employee Plans Compliance Resolution System (EPCRS) in Revenue Procedure 2021-30 that are helpful for plan sponsors as they expand the ability of plan sponsors...more

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

Bracewell LLP

CARES Act Update: IRS Issues Guidance for Amending Partnership Tax Returns

Bracewell LLP on

On April 8, 2020, the IRS released Revenue Procedure 2020-23 (the Revenue Procedure), which provides guidance for partnerships subject to the centralized partnership audit regime under the Bipartisan Budget Act of 2015 (the...more

McDermott Will & Emery

Weekly IRS Roundup January 27 – 31, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 27 – 31, 2020. January 27, 2020: The Joint Committee on Taxation released a report...more

McDermott Will & Emery

Is an Increase in LB&I Assertion of Penalties on the Horizon?

On May 31, 2019, the Treasury Inspector General for Tax Administration (TIGTA) released a report indicating that changes may be in the works regarding assertion of accuracy-related penalties in examinations handled by the IRS...more

McDermott Will & Emery

IRS Expands Self-Correction Program, Provides Welcome Relief for Plan Sponsors

McDermott Will & Emery on

The IRS recently released an updated version of EPCRS, the IRS’s program for correcting errors that occur under tax-qualified retirement plans. The latest version of EPCRS makes it easier for plan sponsors to self-correct...more

Snell & Wilmer

To Err is Human – To Forgive is Up to the IRS in Rev Proc 2019-19

Snell & Wilmer on

The IRS recently issued its latest version of the Employee Plans Compliance Resolution System (“EPCRS”) in Rev. Proc. 2019-19. The EPCRS is the IRS program that assists employers in correcting both operational and document...more

Burr & Forman

Correcting Retirement Plan Errors Just Got Easier

Burr & Forman on

The Internal Revenue Service (IRS) issued Revenue Procedure 2019-19 on April 19, 2019, updating the Employee Plans Compliance Resolution System (EPCRS) to expand the types of plan errors that can be corrected under EPCRS....more

McDermott Will & Emery

Maintaining Retirement Plan Documents after Revenue Procedure 2016-37

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At the 2016 Joint Fall CLE Meeting on October 1, 2016, Andrew Liazos presented on “Maintaining Retirement Plan Documents after Revenue Procedure 2016-37.” As an employer sponsoring a retirement plan, you are required by...more

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