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What is a VCP?

A VCP is a submission to the IRS through its Voluntary Correction Program offered under the Employee Plans Compliance Resolution System (EPCRS). Under VCP, an employer voluntarily discloses to the IRS one or more qualification failures and proposes corrections for those failures. The IRS may negotiate changes to the proposed corrections, but the end result is generally an IRS-approved correction and a compliance statement setting out the failures and the approved corrections. VCP is a valuable option for plans to maintain their tax-qualified status.

VCP is ideal for corrections that:

  • Failures that are not eligible for self-correction

  • Proposed corrections that do not follow the safe harbor correction methods published by the IRS

  • Corrections by retroactive plan amendments, which are generally not eligible for self-correction, unless the plan amendment provides an increased benefit to participants.

IRS VCP fees range between $1,500 and $3,500 based on net plan assets. Other costs involved are the costs of correction and any costs to prepare the submission, such as legal fees. The IRS can take several months to review and close a VCP submission.

Unlike correction under audit, resolution under VCP does not entail the payment of penalties and there is a general presumption of good faith due to the voluntary nature of the submission. Unlike self-correction, VCP provides the certainty of IRS approval of the specific correction methods. Once a VCP is filed, other than an anonymous submission, the plan has audit protection on the specific failures described in the submission.

© Boutwell Fay LLP 2019, All Rights Reserved.This handout is for information purposes only, and may constitute attorney advertising. It should not be construed as legal advice and does not create an attorney-client relationship. If you have questions or would like our advice with respect to any of this information, please contact us.The information contained in this article is effective as of April 30, 2019.

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