Fixing Missed Interims with PPA Restatement and VCP

[Flyboyjohn]

Rather than having client adopt late PPA, HEART and WRERA interim amendments I decided to have them adopt their PPA restatement which incorporates the interims.

VCP application appears to require that I identify where in the PPA restated document the "interims" are reflected which I suspect will be a royal pain.

Anybody know if I can get away with just submitting the PPA restated document since IRS "knows" the interims are incorporated (at least through the 2010 Cumulative List)?

[Lou S.]

If your system has "stock" PPA, HEART & WRERA you might just save yourself some time and have the client sign those 3 amendments with the PPA doc. But as for your suggestion, sorry I have no experience with trying that.

[ETA Consulting LLC]

When you file the Schedule 1, you would print a copy of the amendments from the Basic Plan Document and submit them with your filing. You would, then, explain to the IRS that those amendments were adopted with the preapproved plan. So, when you submit the signed adoption agreement, they will understand that those amendments are incorporated into the Basic Plan Document for the preapproved plan. There would be no need to sign the amendment if you didn't change any of the defaults.

I've submitted several. In one instance, I actually had to clarify to the Revenue Agent that the amendments were part of the BPD and adopted with the adoption agreement. They accepted it.

Good Luck!