Guest Ray Goetz Posted April 20, 1999 Posted April 20, 1999 Has anyone dealt with a 403(B) plan that had a proper employer sponsoring it (a 501©(3) organization), but that had let some employees of a for-profit subsidiary also creep in? Would this be a candidate for TVC and/or APRSC, as now folded into EPCRS? Has there ever been any real IRS enforcement on this point? Any thoughts would be appreciated.
Ellie Lowder Posted April 23, 1999 Posted April 23, 1999 Ineligible employees is not a defect that can be corrected under APRSC - only Operation failures can be self-corrected. Eligibility failures can be corrected under TVC. Refer to Revenue Procedure 99-13 for more information.
Guest CVCalhoun Posted April 26, 1999 Posted April 26, 1999 On the enforcement issue, ineligible employers are one of the key points the IRS Manual instructs agents to raise in auditing 403(B) plans. --------------------------- Employee benefits legal resource site
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