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You Got the Letter! What Now? IRS Pre-Examination Retirement Compliance Pilot Program is Extended

Have you ever received a letter from the IRS and felt that knot of anxiety form in your stomach? It's a common reaction, but there's some good news for retirement plan sponsors: the IRS is extending its Pre-Examination Retirement Compliance Program, offering a unique opportunity for proactive correction before audits begin.

On February 7, 2024, the IRS made an announcement regarding the second phase of this program, building upon the success of its initial launch. Under this initiative, plan sponsors selected for examination will have a crucial 90-day window to review and rectify any plan document or operational errors. This streamlined process aims to reduce the burden of audits on taxpayers, expedite plan examinations, and foster a culture of self-correction within retirement plan management.

Phase one of the program demonstrated notable efficiency, with 72% of the letters prompting proactive responses from plan sponsors. This high engagement rate underscores the value of providing a structured framework for self-correction within the retirement planning landscape.

So, what does this mean for plan sponsors who receive the dreaded IRS letter? First and foremost: act fast. The clock starts ticking as soon as that notification arrives, and it's crucial to leverage every moment of the 90-day window effectively.

Engaging with benefits counsel early in the process is essential. These professionals bring invaluable expertise to the table, helping plan administrators navigate the complexities of plan documents and operational procedures. With their guidance, sponsors can swiftly identify any errors and implement the necessary corrective measures.

The benefits of proactive correction during this window are significant. Eligible errors can be self-corrected, potentially avoiding penalties and mitigating the risk of more extensive audits down the line. By taking prompt action, plan sponsors not only demonstrate a commitment to compliance but also position themselves to maintain the integrity of their retirement plans.

It's important to note that not all errors may be eligible for self-correction. In such cases, plan sponsors still have options. They can request a closing letter from the IRS, which will determine any associated fees using the fee structure of the Voluntary Correction Program (VCP). This approach offers a more favorable fee arrangement compared to the potential costs incurred under traditional audit procedures.

In essence, the extended Pre-Examination Retirement Compliance Program offers a lifeline to plan sponsors facing IRS scrutiny. By embracing this opportunity for proactive correction, sponsors can navigate the compliance landscape with confidence, secure in the knowledge that they're taking decisive steps to safeguard their retirement plans.

In conclusion, if you find yourself on the receiving end of an IRS letter regarding your retirement plan, remember: act fast, engage with benefits counsel, and leverage the opportunity for proactive correction. By doing so, you can turn a potentially daunting situation into a manageable process that ultimately strengthens your retirement planning endeavors.

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