Belgarath Posted June 29, 2020 Posted June 29, 2020 Any reason why the SMM can't function as the Notice, as long as it is given at least 30 days in advance, and the procedures for changing a deferral election are included? DMcGovern 1
Alonzo Church Posted June 30, 2020 Posted June 30, 2020 No, though I would flip the question -- is there any reason why the Notice can't also be an SMM? Beyond making sure you designate the communication as an SMM, I can't think of any change to the notice you would do to make it do double duty as the SMM. CarolC 1
austin3515 Posted June 30, 2020 Posted June 30, 2020 Ha, I've taken both positions! Also Derrin Watson recommended just writing "This SMM is intended to provide updates to the Safe Harbor Notice" or something to that affect to make it clear that it was fulfilling both requirements. Austin Powers, CPA, QPA, ERPA
Belgarath Posted July 1, 2020 Author Posted July 1, 2020 Thanks. Austin, I like this - simple and practical.
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