IRS Updates Procedures for Filing VCP Submissions

The IRS announced on Sept. 28 that it has issued new procedures for using the www.pay.gov website to file Voluntary Correction Program (VCP) submissions and pay user fees. The IRS made the announcement in Revenue Procedure (Rev. Proc.) 2018-52.

Under Rev. Proc. 2018-52, beginning on April 1, 2019, the IRS will no longer accept paper VCP submissions or process user fees paid with a paper check. During the transition period from Jan. 1, 2019, through March 31, 2019, plan sponsors may file VCP submissions with the IRS either by using www.pay.gov in accordance with Sections 10 and 11 of Rev. Proc. 2018-52 or by filing paper VCP submissions in accordance with the procedures in Sections 10 and 11 of Rev. Proc. 2016-51.

Revenue Procedure 2018-52 modifies and supersedes Rev. Proc. 2016-51, 2016-42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (EPCRS), a comprehensive system of correction programs administered by the Employee Plans Division (TE/GE) for sponsors of retirement plans that have failed to satisfy certain requirements under Sections 401(a), 403(a), 403(b), 408(k), or 408(p) of the Internal Revenue Code.

Rev. Proc. 2018-52 will be published in the Oct. 15, 2018 issue of the Internal Revenue Bulletin.