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IRS Revises VCP User Fees

For submissions made on or after January 2, 2018, the user fee to correct a qualified plan operational failure under the IRS’s Voluntary Correction Program (“VCP”) will be based on the total amount of net plan assets rather than the number of participants in the plan. Net plan assets are generally determined using the amount listed on the most recent Form 5500 filed for the plan. Additionally, alternative or reduced fees for certain corrections have been eliminated. Therefore, in some cases fees will be significantly lower than under the prior fee schedule, but in other cases, they will be higher because the prior fee schedule based the fee on the number of affected participants, not the number of total participants.

Below is the new, simplified fee schedule for VCP submissions, followed by the prior fee schedule.

New Fee Schedule: Net Plan Assets   VCP Fee
 • $0 to $500,000   $1,500
 • Over $500,000 to $10,000,000   $3,000
 • Over $10,000,000   $3,500
     
Prior Fee Schedule: Number of Participants   VCP Fee
 • 20 or fewer participants   $500
 • 21 to 50 participants   $750
 • 51 to 100 participants   $1,500
 • 101 to 1,000 participants   $5,000
 • 1,001 to 10,000 participants   $10,000
 • Over 10,000 participants   $15,000

View the new fee schedule, which is set forth in Appendix A, Section .09 (page 223) of Revenue Procedure 2018-4.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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