Missed RMD's for multiple years

[Belgarath]

Situation where census provided by client showed incorrect DOB for an individual, from inception, and it was never caught by the client. Employee terminated, left funds in plan. Now turns out that former employee is in fact several years older than 70-1/2, so multiple years missed RMD's.

So, you self-correct, but under SCP you can't get a waiver of the excise tax, so you file the 5329 with the "reasonable cause" statement. Any thoughts as to the relative merits (or risks) of submitting under VCP solely to try to get a formal waiver of the excise tax? The total tax involved would likely be "only" a couple of thousand dollars more than the VCP fees. I know the IRS has historically been pretty reasonable about waiving excise tax in missed RMD situations, but not sure about a multiple-year situation where VCP is otherwise available.

Also, would you file multiple 5329's - one for each year RMD was missed, or just one 5329 using the total of missed RMD's plus interest as the RMD for, say, 2019?  I'd say the latter, but others may disagree.

[waid10]

Belgarath - I have the same question.  Like you, we have 1 participant for which RMDs were not made for multiple years.  I think SCP still makes sense, but my concern is the 50% excise tax. I am going through the same question regarding whether VCP is worth it for the formal waiver of the excise tax.  If you go with SCP, are you having the employer file the 5329s?  Also, I see your question about one 5329 or multiple (one for each year).  I thought that the participant would have to file amended tax returns for each of the affected years and attach a 5329 with each amended return.