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Guest Article

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(From the June 1, 2010 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)

2010 Work Plan for IRS Employee Plans Office


Seven key operating priorities are outlined in the 2010 Work Plan recently released for the IRS's Employee Plans office.

As part of the Tax Exempt & Government Entities (TE/GE) operating division of the IRS, the Employee Plans (EP) office is focused on retirement plan compliance with the Internal Revenue Code. Its newly announced 2010 Work Plan is aligned with the IRS's larger Strategic Plan, which has two overarching goals, to: (1) improve service to make voluntary compliance easier, and (2) enforce the law to ensure that everyone meets their obligation to pay taxes. With this emphasis on voluntary compliance and ensuring that all meet their tax obligations, the EP's seven operating priorities for this year are:

  • International Issues - Coordinate within the IRS and with international organizations to target significant risk areas using education, determinations, guidance, voluntary compliance and enforcement.
  • 401(k) Compliance Questionnaire - Share the results of the 401(k) Questionnaire with EP stakeholders and use the findings to address noncompliant behaviors using education, determinations, guidance, voluntary compliance and enforcement.
  • Governmental Plans Community - Work with the governmental plans community in collaboration with TE/GE, Federal, State and local governments, and Indian Tribal Governments offices to improve communication (through outreach, education, guidance and self-help tools) and share data (from the Questionnaire, EP sources and the Retirement Plans website).
  • Abusive Transactions - Address and deter abusive transactions by:

    • Promoter Investigations - Using Promoter Investigations to deter the marketing of abusive schemes involving retirement plans.
    • Collaboration - Using cross-functional collaboration to evaluate emerging compliance issues and complex international transactions.
    • Strategy - Developing strategies to identify and address new abusive schemes while considering civil or criminal fraud where applicable.
    • EP Compliance Unit - Using the EP Compliance Unit to leverage coverage and expand compliance contacts into areas of potential abuse or non-compliance.
    • Public Disclosure - Sharing the discovery of potentially abusive schemes and issues of interest to the IRS with the public.
  • Retirement Plans Website - Update the Retirement Plans Website to make it easier to use.
  • Determination Letter Process - Ensure the staggered determination letter process stays on schedule by addressing the expected surge in Form 5307 filings, completing work on preapproved defined benefit plans, analyzing previous cycles, and implementing steps to increase efficiency and more quickly issue determination letters.
  • 403(b) Program - Complete the implementation of a program for IRC§ 403(b) arrangements by opening a pre-approved plan program, and issuing a draft revenue procedure on a program for individually-designed IRC §403(b) arrangements.

Deloitte logoThe information in this Washington Bulletin is general in nature only and not intended to provide advice or guidance for specific situations.

If you have any questions or need additional information about articles appearing in this or previous versions of Washington Bulletin, please contact:

Robert Davis 202.879.3094, Elizabeth Drigotas 202.879.4985, Mary Jones 202.378.5067, Stephen LaGarde 202.879-5608, Bart Massey 202.220.2104, Tom Pevarnik 202.879.5314, Sandra Rolitsky 202.220.2025, Deborah Walker 202.879.4955.

Copyright 2010, Deloitte.


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