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NonAmender - EGTRRA and PPA


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Sole prop, one-participant plan,  since inception 1/1/2005.  Original document is a GUST document.  Has been amended for all good faith required amendments up to EGTRRA, but was not restated for EGTRRA or PPA.

Is the appropriate VCP correction to adopt retroactive EGTRRA and PPA restatements (without any PPA good faith amendments), and can this be accomplished with one "VCP Kit"?  In other words, one set of forms, including Form 14568-B, checking off the appropriate boxes for the EGTRRA restatement and the PPA restatement, with one $1500 fee?

Also, will the IRS disallow the application if the sole prop cannot locate the advisory letter for the GUST volume submitter?

Thanks very much.

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Yes this can all be corrected with EGTRRA & PPA restatements (no interims needed) in one VCP filing.

Don't know if IRS will balk at the absence of the GUST letter but if you still have your GUST document package why not add a GUST restatement to the submission? 

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Thanks John.  I think that the TPA the client was working with originally that prepared the documents he does have is still in existence, so I'm holding out some hope that we can get the letter that way, but in case not I appreciate the suggestion regarding the GUST doc.

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