To the best of my recollection, it goes like this:
1. File late (not DFVCP)
2. Get IRS late filer penalty letter
3. Go through the DFVCP steps, including payment
4. Respond to IRS late filer penalty later with certain information from the DFVCP filing.
Thanks Bill
The article nailed it, perfect.
My concern is how to adjust the assets. BOY assets would be cash and EOY would be accrual. The contributions would cover 2 years, is that an acceptable approach?