PERAC Memo #14 - 2010: IRS Voluntary Compliance Program Update
IRS Voluntary Compliance Program Update
View original on MA State Library →Summary
This memo updates boards on the IRS Voluntary Compliance Program (Cycle C) process, noting that the IRS approved PERAC's adoption of compliance regulations (effective December 11, 2009) as satisfying federal law update requirements for local retirement systems, and that IRS review of individual determination letter applications is now underway with a single assigned agent. Boards need not take any action or respond directly to IRS inquiries regarding their determination letter applications, as PERAC's counsel is coordinating all responses on behalf of the local systems.
Full Text
MEMORANDUM #14, 2010 M E M O R A N D U M TO: All Retirement Boards FROM: Joseph E. Connarton, Executive Director RE: IRS Voluntary Compliance Program Update DATE: March 16, 2010 We are very pleased to let you know that the Internal Revenue Service ("IRS") has approved the adoption of compliance regulations by PERAC as an appropriate federal law compliance update to the provisions governing the local retirement systems. The IRS issued a Compliance Statement approving the adoption of these regulations, applicable to all of the local retirement systems. The adoption of these regulations was completed on December 11, 2009. These activities were a critical step in the new IRS qualification process ("Cycle C") for the local retirement systems. The final step in the Cycle C process is for the IRS to review and approve the determination letter applications for the local retirement systems. We have been fortunate to have all of the local retirement systems be assigned to a single IRS agent, and she has started her review of the applications. Our counsel is now working directly with the IRS to provide any additional information needed to complete this process, so you do not need to respond to any inquiries you may receive relating to your system's determination letter application—our counsel is coordinating responses to the IRS for all of the local systems. (We note that it is possible during this review that some changes to the PERAC regulations may need to be made, but we expect those would not be significant.) While we cannot project when the IRS will complete their review, upon completion a determination letter will be issued to each of the local systems confirming that the governing plan documents comply with the governmental pension plan federal law requirements. If you have any questions, please feel free to contact General Counsel, Barbara Phillips or Deputy General Counsel, Judith Corrigan.