IRS Updates Procedures for Exceptions from Certain Electronic Filing Requirements
On September 13, 2023, the IRS issued Revenue Procedure 2023-31, which addresses requests for undue hardship waiver or administrative exception from the electronic filing requirements for Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, and Form 5500-EZ, Annual Return of A One Participant (Owners/Partners and Their Spouses) Retirement Plan or A Foreign Plan. The Taxpayer First Act of 2019 requires taxpayers filing at least 10 returns during a calendar year to file Forms 8955-SSA and 5500-EZ (among other returns) electronically. The IRS subsequently released final electronic filing requirements earlier this year. Rev. Proc. 2023-31 supersedes Rev. Proc. 2015-47 and indicates that for filings submitted with respect to plan years beginning on or after January 1, 2024, the procedures for seeking hardship waiver or administrative exception from the electronic filing requirements for Form 8955-SSA or Form 5500-EZ will be available in the instructions to those forms or other IRS guidance or postings.
