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austin3515

IRS Pension Plan Burden Survey

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Are people responding to this? I have a client who has received 3 reminders to complete this "voluntary" survey?

Please advise what you guys are doing?

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https://www.irs.gov/statistics/2017-pension-plan-burden-survey

Over the last few months.  They're asking questions and the client is thinking (and me too) that the questions might sound benign, but if they answer wrong will that trigger an audit?  For exmaple, one quesiton is "Who has all of the plan records?  a) The Employer, b) the recordkeeper or c) the TPA.

If they tell the truth and say recordkeeper will the IRS be "horrified" at the dereliction of duty?

And if they don;t respond will the IRS say "hmm... they didnt respond voluntarily, so maybe I'll subpoena them" (I've been watching too much news!).

Are we overthinking this?

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austin3515, my guess is you're overthinking this. The IRS cover letter says they'll only use for research, and Westat is an independent research organization. Having said that, it doesn't seem to promise that the answers will be confidential and not shared by Weststat with IRS. It might behoove you or your client to call Weststat at number provided and seek reassurance as to use of data.

Years ago there was a much more intrusive survey that was sent around, as you may recall, and my clients did not seem to have audits as a result.

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I get the skepticism of their motives and trustworthiness, but if their questionnaire is revealing what you believe to be bad practices, maybe take the opportunity to revisit plan practices?

The IRS has been doing this survey stuff all across the board for all types of taxes and taxpayers.  It's why most IRS instructions include the number of hours they estimate the form will take you to complete.  This survey is how they guess that and they are asking for your help updating their guesses.  "Who has the data?" is directly relevant to how long it takes to complete a form.

If they wanted to ask you questions to identify bad practices that might trigger an audit, they would put those questions on the regular reporting form and ask it of everybody.  And in any case, I am not sure why the IRS would care about bad recordkeeping practices so much they would audit you - unless they can levy a tax or penalty, or maybe initiate a criminal case, I do not think they especially care.  EBSA might care about bad practices, since they see themselves as protecting participants and catching infractions, but they generally cannot levy penalties or taxes.  But the IRS is about that money.

But if it's voluntary and you do not want to gift them your time to complete their survey data, I guess chuck their letters in the trash.

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