New Rev. Proc. on EPCRS

[david rigby]

https://www.irs.gov/pub/irs-drop/rp-16-51.pdf

[Griswold]

never a dull moment!

[RatherBeGolfing]

So much for a relaxing weekend...

[BG5150]

Anything major?

I, too, will be perusing it this weekend, but was jsut wondering.

[Belgarath]

I did nothing more than speed read the section in the beginning where it lists the changes, and it didn't appear to be much of a change. Largely just incorporating prior changes, modifications due to the determination letter program changing, some minor clarifications, moving stuff from one section to another, modifying the Appendix C Schedules, etc...

[Tom Poje]

same as Belgarath, simply looked at the changes, though I did look at

Appendix B, plan amendment to include ineligible, and the example still says submit for determination letter.

everywhere else they seem to say don't do this so I wonder if they simply missed on this item

of course, I guess anything is EPCRS including examples is 'definitely ok' and if you don't submit for a letter you are 'possibly taking your chances' but in light of the fact the IRS has practically begged you not to submit....

[EBECatty]

The new Rev. Proc. eliminated the 50% refund for anonymous submissions failing to reach resolution, which I use on occasion. Always thought this was a good feature in iffy cases, so that's unfortunate.