Belgarath Posted December 20, 2017 Posted December 20, 2017 Filed a very basic VCP on a SIMPLE-IRA plan in June. Received an acknowledgement letter in mid-AUGUST. Called twice recently to check status. In spite of the IRS voice mail promising a call-back within 2-3 business days, it took 7 business days, but at least they did call. I didn't speak to the person - they left me a voice mail, but it has NOT YET BEEN ASSIGNED TO A REVIEWER. It will be "at least several weeks" before it is even assigned. Just an fyi to prepare yourself to hurry up and wait...
Peter Gulia Posted December 20, 2017 Posted December 20, 2017 I've heard practitioners express differing views about whether it matters how quickly or slowly the Service acts on VCP submissions. Some say a client might perceive a long lag as somehow suggesting the practitioner's lack of care or diligence. Others say a wait is fine because a taxpayer is protected once it has filed the submission. And some say a lag might even help because a practitioner might "supplement" a submission to include further errors. What do BenefitsLink mavens think? Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
MoJo Posted December 20, 2017 Posted December 20, 2017 FGC: I think people tend to overthink hings like how long the VCP filing takes. Yes, you can "supplement" with other errors/issues - but we do a complete (as complete as possible) audit to uncover other issues that should be included. The "one" rule we hold virtually inviolate is to "not poke the bear" once the filing has been made. Our experience has been that when awoken, the "bear" is in a bad mood and that hasn't bode well for the outcome. The IRS has been made to "starve" for ideological reasons. Those that remain tend to be believe they are overworked (and underpaid), and when left alone, when their internal "metrics" indicate they are falling behind, a lot happens in a short time and we get the compliance letter sought. I hate to say that, but that has been our experience....
Belgarath Posted December 20, 2017 Author Posted December 20, 2017 I don't think you can give an answer that fits all situations. I'd say that generally, however, clients want closure/certainty, which doesn't exist while the application is pending, so they can get frustrated. However, they certainly don't blame me because the IRS hasn't yet even assigned it to a reviewer.
ETA Consulting LLC Posted December 20, 2017 Posted December 20, 2017 44 minutes ago, Fiduciary Guidance Counsel said: Others say a wait is fine because a taxpayer is protected once it has filed the submission. This is what I say. I filed a VCP Submission back during the summer for a non-amender. Filed another one back in October. I received the Compliance Statement for the one I filed in October. The one I filed during the summer is still pending. You can only imagine the chaos that goes on behind those doors. Ultimately, it goes to accountability; who's making who do their work? I've had submissions that lasted for a couple of years; even the simple ones (not to be confused with SIMPLE IRA, but merely a streamlined submission). Once filed, you're immune to the failures included withing that submission. Good Luck! CPC, QPA, QKA, TGPC, ERPA
John Feldt ERPA CPC QPA Posted December 20, 2017 Posted December 20, 2017 Approvals were recently received for two that were submitted in August and September, one was nonamender, the other was a 'regular' submission (nonamender plus other issues). No questions asked! Seemed faster than usual for a reply, but we'll accept.
AndrewZ Posted January 23, 2018 Posted January 23, 2018 I filed one in early April 2017, a one-participant-plan non-amender. Should be a rubber-stamp. I just heard from them again that it hasn't yet been assigned to an agent. Andrew, ERPA, CPC, QPA
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