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The Illusory Benefit of the IRS's Proposed Correction to the MEP 'One Bad Apple' Rule
Business of Benefits Link to more items from this source
[Guidance Overview]
July 12, 2019
"The 'bad apple' problem has always sounded worse than it is and may have been able to be fixed by a simple adjustment to the Maximum penalty Amount rules under EPCRS, and to the rules as to who should be responsible for that penalty.... The most difficult logistical and legal challenges facing MEPs ... are in the forced spin-off of a recalcitrant participating employer. The IRS proposal only really addresses small part of what actually happens under these circumstances[.]"

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