IRS Modifies VCP Fees for 2018

By John Iekel • January 03, 2018 • 0 Comments

The IRS’ first Revenue Procedure of 2018, Rev. Proc. 2018-01, provides the usual — an explanation of how it provides advice to taxpayers on a variety of issues — but it also contains something else. The IRS also reports that for 2018, it has modified the fees for voluntary correction program (VCP) filings, as well as other user fees.

Changes to Fees for VCP Submissions

The IRS modified the user fee structure for VCP submissions so they are now as follows:

  • $1,500 for plans with assets of $500,000 or less;
  • $3,000 for plans with assets of over $500,000 to $10,000,000; and
  • $3,500 for plans with assets of over $10,000,000.
The IRS made no changes to the user fee for group submissions, nor to the special fee waiver for terminating orphan plans.

Increases in Other Fees

The IRS also has increased the user fees for the following types of submissions:

  • for opinion letters on prototype individual retirement accounts and/or annuities, SEPs, SIMPLE IRAs, SIMPLE IRA Plans, Roth IRAs and dual-purpose IRAs, the IRS raised the user fee from $1,000 to $2,500; and
  • for Form 5310 (Application for Determination for Terminating Plan), the IRS raised the user fee from $2,300 to $3,000.

Comments (10)

Are all the lowered fees gone, except for orphan and group? In section 2 it states: "All other reduced or alternative fees previously set forth... Read more
1/5/2018 4:23 PM
John Feldt
The reduced fee for missed RMD's has been eliminated and this is very unfortunate. I am not sure why the IRS is now requiring an increased fee f... Read more
1/5/2018 4:04 PM
Judy Simons
The linked document is a concatenation of several documents. If you look carefully, it is Rev. Proc. 2018-04 that contains the VCP (and other EP) us... Read more
1/5/2018 3:44 PM
James E Holland, Jr
It looks like fees were increased for the small plan marketplace. It is not unusual for plans to have more than $500,000 of assets. Prior to 2018... Read more
1/5/2018 3:40 PM
Steve Resnikoff
Did the reduced fee for Non-Amenders go away?
1/5/2018 3:10 PM
David Danziger
How are the fees reduced? Could you provide some examples or comparison? For a small employer, or a not-for-profit, or even a large plan relying on ... Read more
1/4/2018 7:08 PM
Marie Newsham
Did the reduced user fees for items such as participant loan and RMD failures go away under this Rev Proc?
1/4/2018 4:24 PM
Steven Ogden