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Has the IRS Changed Its Position on VCP-Triggered Audits?
American Retirement Association [ARA] Link to more items from this source
July 20, 2021

"Nothing in the [Internal Revenue Manual] requires a referral and there has been no other policy change regarding referrals. Plan sponsors who are concerned about their ability to reach an agreement on correction methodology should consider submitting their applications anonymously before Jan. 1, 2022, and after 2021, requesting the new anonymous pre-submission conference announced in Revenue Procedure 2021-30 to determine whether the desired correction may be permissible."

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