IRS Audits / settlements

[Guest FAQ]

A new client has a noncompliant arrangement that was not timely amended and is not covered by the document correction program. There is no IRS involvement at this point but based on the proposed income inclusion regs, the penalties and interest alone will be significant.

Has anyone been involved with negotiating an IRS settlement following the discovery of a 409A violation that is not eligible under the correction programs?

Does anyone know whether the IRS is willing to negotiate with taxpayers who come forward? Or is the IRS going for every last dime?

Also, does anyone know who or what office at the IRS is spearheading the 409A enforcement initiatives? We'd like to put out some feelers.

Thanks in advance.

[Guest bobolink]

I have nothing of substance to add, but am very interested in this subject and want to receive alerts if others post. Thanks for posing the question, FAQ.