5500 statute of limitations

[ESOP Guy]

I can't seem to find anything on this so maybe there is no limit. We are working on a correction to a plan that goes back to 2005. We are going to file for a VCP on the correction. The question came up about the 5500s. I was thinking you couldn't amend them after 3 years like many of tax returns but I can't find that in writing so I am thinking I am just plain wrong.

So I guess the questions is can you amend 5500s that old or are those years closed?

[Bill Presson]

You can find all of them here:

http://www.irs.gov/irm/part25/irm_25-006-001r.html

[Flyboyjohn]

My understanding of unoffical DOL policy:

If no 5500s ever filed go back to LATER of 1999 (I think that was when 5500s switched from IRS to DOL)or date delinquncy began.

But, in recognition of difficulty in constructing accurate returns for possibly 20+ years DOL will accept filings that are "perfect" for the latest 3 years and then "best efforts" for prior years.

Janice Wegesin is the guru on these questions.