Section of Taxation
Submission to the Executive Branch

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Comments on the Voluntary Fiduciary Correction Program

  1. Form 5500 Implications

    Background: Corrections made under the Program may require changes to previously-filed Forms 5500. For example, there may be a need to report a prohibited transaction for a prior plan year, or to correct the value of assets described for one or more prior plan years (as required in the correction procedure in Section 7.D. of the Program release, dealing with improperly valued assets).

    Comment: Failure to file a complete and accurate Form 5500 can result in penalties under ERISA and the Code. The possibility of incurring such penalties will discourage use of the Program.

    Recommendation: Penalties related to Form 5500 filings should be waived where a previously-filed Form 5500 is being amended as part of the correction process under the Program.

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