Hi, I’m Danielle.  When your Voluntary Correction Program submission arrives at the IRS, it will be screened by someone like me. If I find problems with your submission, I will send you a letter asking you to correct them. Errors cause delays. Your submission may even be returned to you if the errors are not corrected on time. Since we do not want this to happen, here are some tips for completing your submission correctly.

To make things easier for you, you can use the fillable PDFs on our website. If you use your own version of the forms, please do not make changes to the format such as using your own letterhead or changing the wording.  Also, please do not delete any of the checkboxes on the form, such as plan types or schedules included with your submission, even if the empty checkboxes do not apply to you.  

Your VCP submission will ask for the number of participants in your plan. If your plan files a Form 5500, 5500-SF or 5500-EZ, this number will be shown on your most recent return. It’s line 7f on the 2010 5500. If you have a SIMPLE IRA, SEP or other plan that’s not required to file a 5500 return, put down the number of employees who participated in your plan at the end of your most recent plan year. Do not leave this question blank even if your plan doesn’t file a 5500.  Also, if you sponsor a multiple employer plan, the number of participants should be the total number of people in the plan, and not the number of participating employers.

The next question asks for the assets in the plan. Again, if you file a 5500, 5500-SF or 5500-EZ, this number is based on your most recently filed form. For IRA-based plans, you can use an estimate of the assets in the plan. The number could be based on your total contributions to the SEP or SIMPLE IRAs of the participants.  Just don’t leave it blank.  Also, if your plan terminated, you should use the last amount in the plan before the termination date.

Let’s move on to the page labeled “Applicant’s Representations.”  This page requires the plan sponsor to certify that the plan is not being audited, that no abusive tax transactions have occurred, and certain other things. Be sure the plan sponsor checks one of the boxes in item B! We cannot check it for you, and you cannot check both boxes. This section has to be signed by the plan sponsor, not the person with the power of attorney. If you are a practitioner, proofread the copy your client sends you to make sure that it is filled out correctly and signed before sending it on it to the IRS.  

Thank you for listening. If you have more questions about the Voluntary Correction Program, be sure to visit us on the Web at www.irs.gov/retirement.