Regulatory Updates

IRS Posts Updated Form 8950 for VCP Applications

The IRS has posted a 2022-dated version of Instructions for Form 8950, Application for Voluntary Correction Program (VCP) under the Employee Plans Compliance Resolution System (EPCRS). The form is used when correcting certain retirement plan failures under the IRS’s VCP, and reflects changes to the VCP pursuant to IRS Revenue Procedure 2021-30.

For example, the instructions indicate that as of January 1, 2022, the IRS no longer permits VCP submissions to be made on an anonymous basis (pre-submission conference requests can now be made to discuss correction methods not described as safe harbor correction methods under EPCRS). The instructions will be reviewed further, and any items of significance will be shared.