On June 3, 2022, the IRS announced a new pilot pre-examination compliance program for retirement plans beginning in June 2022.  Under the new program, the IRS will send letters to plans advising them that they have been selected for an examination and will have a 90-day window to self-review the plan’s documentation and operation to determine if they meet current tax law requirements. If the plan does not respond within 90-days, the IRS will audit the plan. If self-review reveals non-compliance, the plans will be able to self-correct the mistakes using the correction principles in the IRS voluntary compliance program (EPCRS).  

EPCRS’s self-correction program will be available. If a mistake cannot be self-corrected, an IRS closing agreement under EPCRS will be available based on the voluntary compliance program (VCP) fees rather than the normal closing agreement fees.

If the plan does respond within 90 days, the IRS will review the submitted documentation, determine whether it agrees and enter into a closing agreement. If the IRS does not fully agree that appropriate corrections have been made, the IRS will conduct either a limited or full scope examination.

The IRS views the program as a way to reduce the taxpayer burden and the amount of time that the IRS spends on examinations. To date, the IRS has just issued an announcement of the pilot program but not provided full details.

For questions or more information in how this program may affect your plan, please contact us here. 

 Full IRS Announcement:  https://www.irs.gov/retirement-plans/employee-plans-news

IRS Employee Plans Compliance Resolution System (EPCRS):  https://www.irs.gov/retirement-plans/employee-plans-news

IRS Voluntary Correction Program Fees:  https://www.irs.gov/retirement-plans/voluntary-correction-program-fees

On March 29, 2021, the Office of Labor-Management Standards (OLMS) released News 01-2021 – Notice of a non-enforcement policy in connection with an intended rulemaking to rescind the Form T-1 Trust Annual Report.

On March 11, 2021 the American Rescue Plan Act became law. It makes important changes to relief available for Labor Unions and Benefit Funds.

Please see our bulletin for additional information.

ARPA Bulletin

The Office of Labor-Management Standards (OLMS) Department of Labor (DOL) is expected to publish a Notice of Proposed Rulemaking (NPRM) to modify the existing Form LM-2 and to establish a LM-2 Long Form (LM-2 LF).

Please follow this link for our client bulletin:

Bulletin

Copies of the draft LM-2 and LM-2 Long Form can be accessed by following these links:

Draft - LM-2

Draft - LM-2 Long Form

Please contact us for additional information

We have provided sections below specific to your client type. Please check back to this page periodically for updates and further information.

Relief available to clients from these Acts

Labor Unions
       Eligible for:
       Employee Retention Tax Credit
       EIDL Loan or Advance

      Employee Retention Tax Credit (for Unions)
      How these programs interact with each other
      SBA Payroll Protection Program and Economic Injury Disaster Loans
      Tax filing extensions

Welfare and Pension Plans
       Eligible for:
       Employee Retention Tax Credit
       EIDL Loan or Advance

       Note: If the benefit funds utilize a TPA there is a chance
       that a Payroll Protection Loan would be available to the TPA.

       Employee Retention Tax Credit (Welfare and Pension Plans)
       How these programs interact with each other
       SBA Payroll Protection Program and Economic Injury Disaster Loans
       Tax filing extensions

501(c)(3) entities (such as training funds)
       Eligible for:
       Payroll Protection Program Loan
       EIDL Loan or Advance

       Information on Payroll Protection Program
       SBA Payroll Protection Program and Economic Injury Disaster Loans
       Tax filing extensions

Annuity and Defined Contribution Plans
       Withdrawal changes for annuity and DC plans
       Tax filing extensions

Our
firm has been deemed “Life Sustaining” which allows us to remain open. Please see our bulletin regarding our ongoing operations:

We're Open for Business

The Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Families First Coronavirus Response Act both provide potential relief for nonprofit associations.

We are still awaiting important details on the many provisions of the Acts, but we wanted to provide a summary of some of the programs which will be of interest to our Union clients. We will update this bulletin as additional information becomes available.

Update for Union Clients

The Treasury Department and the Internal Revenue Service has provided
special tax filing and payment relief to individuals and businesses in response
to the COVID-19 Outbreak, by extending the 2019 tax filing deadline from April
15, 2020 to July 15, 2020. Please see our bulletin below for more information: 

Bulletin

Please see the bulletin below providing information regarding our response and current resource plan:

COVID-19 Response

We have provided a summary listing the Tax Rates and Limits in effect for 2020. The list includes payroll tax limits, the standard mileage rate as well as other limits.

2020 Rates and Limits

Please contact us for additional information