Anatomy of an IRS Audit. MASBO December 10, 2013. IRS Circular 230 Disclosure.
December 10, 2013
This information is provided for educational and informational purposes and is not intended to be used to avoid tax penalties or to render tax or legal advice. The taxpayer should seek advice from an independent tax and/or legal advisor.
2. Do a “Self-Audits” using both the IRS audit checklist and a copy of what is being asked for currently.
10. Ineligible Employers
NOTE: 95% of all 457(b) plan audits have employer errors.
1. Not all TPAs are created equally!
2. Not all Vendors are created equally!
403(b) Plan document failures
If the Employer did not adopt an updated 403(b) plan by 12/31/2009, the new procedure contains an easy method to correct this by adopting a plan now. If you submit this to the IRS by 12/31/2013 it will only cost you ½ of the normal IRS compliance fee.
 Reduced Fee only applies if the sole failure is the Plan Document Failure
 Proceed cautiously, IRS has indicated that this does not always pass IRS audit.
The remedial amendment period allows sponsors to retroactively fix a written plan failure back to January 1, 2010.
IRS VCP Fees
A new requirement for a 403(b) Employer that is correcting through EPCRS is a certification from all vendors that they will cooperate with the Employer in the correction of the failure(s) as outlined by the IRS.
The certification also includes providing the needed data for the VCP application.