SECTION 2. EFFECT ON PROGRAMS

.01 Effect on programs . This revenue procedure affects the programs as follows:

• consolidates and coordinates guidance issued in 1998 and 1999 into a unified EPCRS procedure;

• clarifies the application of FICA and FUTA taxes (and corresponding withholding obligations) to corrected Qualified Plans and 403(b) Plans; and

• clarifies that the statute of limitations for purposes of redetermining taxes for a closed taxable year will not be reopened solely because of correction of a failure that occurred in such year. .02 Effect on specific programs . This revenue procedure affects the specific programs as follows:

(1) APRSC . APRSC enables a sponsor of a Qualified Plan or a 403(b) Plan to self-correct Operational Failures it discovers in its plans. The provisions of APRSC are modified and restated to:

• clarify and confirm, under the eligibility requirements for APRSC, that the program is available to correct insignificant defects in plans of all sizes. (2) VCR . The VCR program enables a sponsor of a Qualified Plan to voluntarily disclose to the Service Operational Failures it has discovered in its plan and to pay a fixed fee to the Service. The provisions of VCR are modified to:

• grant, in appropriate cases, a waiver of the excise tax under §4974 for minimum required distribution failures that are corrected by the Plan Sponsor under VCR;

• amplify the permissible correction methods under the Standardized VCR Program (SVP) (see Appendix A and Appendix B of this revenue procedure); and

• clarify that sponsors may use Walkin CAP for interrelated VCR and Walk-in CAP failures.

(3) Walk-in CAP . Walk-in CAP enables a sponsor of a Qualified Plan to voluntarily disclose to the Service Qualification Failures it has discovered in its

plan and to pay a compliance correction fee. The provisions of Walk-in CAP are modified to:

• grant, in appropriate cases, a waiver of the excise tax under § 4974 for minimum distribution failures that are corrected by the Plan Sponsor under Walk-in CAP. (4) TVC . Similar to Walk-in CAP, TVC enables an employer that offers a 403(b) Plan to voluntarily disclose to the Service 403(b) Failures it has discovered in its plan and to pay a compliance correction fee. The provisions of TVC are modified to:

• grant, in appropriate cases, a waiver of the excise tax under § 4974 for minimum distribution failures that are corrected by the Plan Sponsor under TVC.

• clarify the types of failures that may be corrected under TVC.