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vcp for non amenders


k man
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client has a MP and a PS that have not been amended for GUST or EGTRRA. they want to get rid of the MP. is it necessary to bring both the MP and the PS into the VCP program and then merge the MP into the PS or can i first merge the MP into the PS and take the merged PS into VCP. this would cause the emoloyer to only have to pay one compliance fee. however, my inclination is you have to submit both plans.

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I would have no reservations about merging the plans and submitting one application. The amendments have to be drafted to apply to both plans back to the beginning of the date of failure, but I can't imagine why the IRS would object to one VCP in the case of properly merged plans, even if it were done on the eve of a filing.

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