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Full-Text Articles in Taxation-Federal
Recent Irs Guidance Provides A Degree Of Certainty For 403(B) Plans, Gregory L. Needles, Christina Payne-Tsoupros
Recent Irs Guidance Provides A Degree Of Certainty For 403(B) Plans, Gregory L. Needles, Christina Payne-Tsoupros
Journal Articles
The IRS has released long-awaited guidance expanding the availability of self correction for 403(b) plans and opening the pre-approved plan program. On Dec 12, 2012, the IRS released Rev. Proc. 2013-12, 2013-4 IRB 313, which expanded its self-correction program -- the Employee Plans Compliance Resolution System (EPCRS) -- for 403(b) plans. On 3/28/13, the IRS issued Rev. Proc. 2013-22, 2013-18 IRB 985, opening its 403(b) pre-approved plan program. The broader scope of correction under Rev. Proc. 2013-12 is a welcome relief to 403(b) plan sponsors, who may now take advantage of EPCRS to remedy mistakes and avoid plan disqualification in …
Embracing The Queen Of Hearts: Deference To Retroactive Tax Rules, James M. Puckett
Embracing The Queen Of Hearts: Deference To Retroactive Tax Rules, James M. Puckett
Journal Articles
The Supreme Court’s decision in Mayo Foundation for Medical Education and Research v. United States underscored the importance of a uniform approach to judicial review of administrative action; accordingly, the Court clarified that tax administration is generally subject to the same review as other kinds of administrative action by other federal agencies. Tax guidance from the IRS and Treasury Department serves an important role in clarifying the tax law so that taxpayers may report their tax liability accurately and plan their affairs. Meanwhile, aggressive attempts by a relatively small number of taxpayers to avoid tax liability by exploiting arguable ambiguities …