Impact of Anonymous VCP submission on NTIP requirements

[Guest KennyH]

I'm not entirely sure where to put this, so if you think there is a better forum, please let me know.

We are preparing an anonymous VCP submission for non-amender failures (will be using Schedule 2). The final submission will include a concurrent determination letter application. I am wondering if the timing of the notice to interested parties is impacted by this process.

Assuming the answer is no, the standard notification period is 10-24 days prior to filing, however, we will have 21 days to provide the submission to the IRS once an agreement is reached. Assuming it takes a week for us to actually receive notification an agreement has been reached, we have a fairly short window to provide the ntip. Perhaps just a couple of days.

I want to verify this is correct so I can warn the plan sponsor they will need to be ready to pull the trigger on the notification asap.

TIA!

[Kevin C]

I'm curious about why you would be using an anonymous filing for a non-amender. I've done several non-amender vcp filings and have not had any issues over the amendments. I have had them request that the filing be redone in a certain way and I've had disagreements with them over what the filing fee is. But, I haven't had any experiences that ever made me doubt that the filing would be approved.

[Everett Moreland]

I agree with Kevin C. I've submitted several nonamenders and nothing occurred that made me wish I'd filed anonymously.