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EPCRS Provides Flexibility for Unlisted Failures and Corrections
FIS Relius Link to more items from this source
[Guidance Overview]
Dec. 11, 2012
"One of the most important things EPCRS (Rev. Proc. 2008-50) gives us is a list ... of common failures and how to correct them.... But EPCRS gives us something else as well: flexibility. The plan can correct an eligible failure even if it is not on the list. Even if the failure is on the list, the plan can follow a different correction methodology. The list is essentially a set of safe harbors, but the ability always exists to fashion an alternative, although without any assurance that the IRS will accept that alternative unless the plan administrator files under VCP."

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