Retirement Plans FAQs regarding the Audit Closing Agreement Program
The frequently asked questions and answers provided below are for general information only and should not be cited as any type of legal authority. They are designed to provide the user with information required to respond to general inquiries. Due to the uniqueness and complexities of Federal tax law, it is imperative to ensure a full understanding of the specific question presented, and to perform the requisite research to ensure a correct response is provided.
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What happens if the IRS and Plan Sponsor fail to reach resolution regarding the appropriate correction of a failure?
Under Audit CAP, if the IRS and the Plan Sponsor cannot reach an agreement with respect to the correction of the failure(s) or the amount of the sanction, the IRS will pursue disqualification of the plan.