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IRS Announces New Pilot “Pre-Audit” Compliance Program for Retirement Plans


On June 3, 2022, the IRS announced a new pilot pre-examination compliance program for retirement plans beginning in June 2022.  Under the new program, the IRS will send letters to plans advising them that they have been selected for an examination and will have a 90-day window to self-review the plan’s documentation and operation to determine if they meet current tax law requirements. If the plan does not respond within 90-days, the IRS will audit the plan. If self-review reveals non-compliance, the plans will be able to self-correct the mistakes using the correction principles in the IRS voluntary compliance program (EPCRS).  

EPCRS’s self-correction program will be available. If a mistake cannot be self-corrected, an IRS closing agreement under EPCRS will be available based on the voluntary compliance program (VCP) fees rather than the normal closing agreement fees.

If the plan does respond within 90 days, the IRS will review the submitted documentation, determine whether it agrees and enter into a closing agreement. If the IRS does not fully agree that appropriate corrections have been made, the IRS will conduct either a limited or full scope examination.

The IRS views the program as a way to reduce the taxpayer burden and the amount of time that the IRS spends on examinations. To date, the IRS has just issued an announcement of the pilot program but not provided full details.

For questions or more information in how this program may affect your plan, please contact us here. 


Full IRS Announcement:

IRS Employee Plans Compliance Resolution System (EPCRS):

IRS Voluntary Correction Program Fees:

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