thepensionmaven

As one TPA to another, it is another designation, and one that is obviously rare since there are so few, and sets us apart from other TPAs. (IMHO) As well, for non-attorneys and non CPAs, we can represent clients in front of IRS and audits, this giving us the advantage of levying a higher fee. After all, you get what you pay for, right???

I renewed in July, 2025 for the 22,23 and 24 years. I showed the proper number of credits. First IRS said they never received my renewal and was placed on inactive. I know they received as they cashed my check I was told I'm 16 credits shy as well as 6 Ethics, which I am not. I wrote a "reasonable cause" as I had an 6 month recovery from two torn retinas, and asked for either a waiver or extension to obtain the necessary credits - just in case they are correct. How would I show the I completed and received the "additional" credits A new Form and go back to 2022 and list all credits, as well as pay another $140, or write in and tell them I have completed and show my backup? In the meantime I was told by an auditor that I can use Form 8821, but obviously can not represent myself as an ERPA until this is straightened out, which, pgiven the furlough could take another 90 days. Are they doing this to others in the hope that they can reduce the number of ERPAs (which is already ridiculously low)?

From the instructions, the years would be 2022, 2023 and 2024 since the enrollment expires 9/2025. Calendar years are used.

From experience, if you have other attachment, like a letter of Reasonable Cause", DOL does NOT forward to IRS.

Someone is confused and I hope it's not me. I was reading someone's post and i believe it read "you can't avoid LTPT. I was also reading a few articles that one will never need to be concerned as long as the plan is amended, if need be, for eligibility to be eligible for plan entry to delete reference, by amendment, to elapsed time, 1 year for deferrals, safe harbor (of course) but leave the provision and any reference to 1 year/1,000 hours only to employer non-elective contribution. I'd be curious how many have done this and if not, why not.

Penalty takes too much time and headaches and is up to the reviewer. DFVC is mostly automatic, gratifying and isn't your time worth at least an additional $750?

Difference between billing and actually getting paid?

We had a similar situation last year, filed the original with letter of Reasonable Cause. IRS came back with $4500 penalty letter, client, not knowing what this was for,saved for accountant l, who not knowing what this was, paid the bill. Client then gets IRS abatement. Wants to know if he can get the money back. I told him since he already paid, IRS considers the matter closed.

Regrettably, I believe it would. Have had this same situation multiple times.

Client has sold the assets of their LLC, employees received their last paycheck 9/2/2025 and were obviously notified of the plan closing. The business is not closing, and the new owners do not want the responsibility of the existing plan. Can the plan termination date be 12/31/25 even though the employees were off payroll earlier? In order to calculate the employer contribution, obviously a P&L is needed; I have not yet seen a P&L for less than a 12 month period.

Good point, thanks. Woold not a DFVC filing for the same plan for two consecutive years prompt an audit? We were visiting the DFVC calculator page ready to start, but were prompted with a prior DFVC submission that had not been paid? Have the changed the page and not allowed since apparently not paid? Never seen this before. No DFVC filing had been made for their year of question, 5500-SF filed 10/16 and they want a $750 fee?

Another musing. My client received an audit letter and we are representing them. We have some of the material, asked a two week extension which was granted pre-furlough for and granted. He asked for the information to be received by 10/22 and his reply emailmentioned something about sanctions if material not supplied. Since the furlough, I wonder if I can ask for another extension, I can't really call the gentleman and request another one week extension "because he's on furlough" Would like some suggested wordings here.

Unable to retrieve American Funds Funds Trust Reports have been unable to be produced due to "IT problems with restructuring the Trust Reports to the old platform" and these have not been able to be made available. Since the beginning of October. This will affect some clients who have been waiting for the Trust Reports as I always compare these with clients' records. I consider this a Reasonable Cause, but the communication with IRS usually takes a few months. I have always been advised to wait until all information is available to file rather than just filing nebulously ax the client signs no perjury as he signs Form 5500-SF. Thoughts, comments?

Entirely my fault, I was. not able to get a couple of SFs and EZ done by 10/5 (I understand 10/16 has usually been OK. The filings went though and were marked as "filing received", which is all my software vendor gives on their receipt of filing, with date and acknowledgement ID for both SF and EZ and the client had signed the form October 15, but I assume forgot to send it to me for submission. The EFAST website lists the filing as "filing received" with a copy of the form and the date the client signed it. Since the client obtained the "filing received", and the filing did not go through with the "warning" instead of the "approved" from the software vendor, edit checks, is there anything to worry about, ie a love letter from Rosie the IRS robot?

Thank for information. Would be practical for the IRS "amnesty" program to be done electronically with a credit card, as well; just as DOL DFVC.