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Corrections Under the IRS Voluntary Compliance Program (“VCP”)

This month’s Building Block discusses the IRS Voluntary Compliance Program, including what it is, how it differs from other correction programs, the types of plans and errors that are eligible, and more.

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Generally, the Internal Revenue Code (Code) requires all unvested benefits to immediately vest when the (tax-qualified) plan is either terminated or the plan experiences a “partial termination.” A

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