Identification of failures. VCP is not based upon an examination of the plan by the Service. Only the failures raised by the Plan Sponsor or failures identified by the Service in processing the application will be addressed under the program, and only those failures will be covered by the program. The Service will not make any investigation or finding under VCP concerning whether there are failures.
Identification of failures. A complete description of the failures, the years in which the failures occurred, including closed years (that is, years for which the statutory period has expired), and the number of employees affected by each failure.
Identification of failures. The VCR program is not based upon an examination of the plan by the Service. The Service will not make any investigation or finding under the VCR program concerning whether there are Operational Failures. Only the Operational Failures raised by the Plan Sponsor or Operational Failures identified by the Service in processing the application will be addressed under the program, and only those failures will be covered by the program. However, because the VCR program does not arise out of an examination, consideration under the VCR program does not preclude or impede (under § 7605(b) or any administrative provisions adopted by the Service) a subsequent examination of the Plan Sponsor or the plan by the Service with respect to the taxable year (or years) involved with respect to matters that are outside the compliance statement. A Plan Sponsor's statements describing Operational Failures are made only for purposes of the VCR program and will not be regarded by the Service as an admission of a failure for purposes of any subsequent examination. If the plan failures include failures correctable under VCR and failures correctable under Walk-in CAP, (e.g., interrelated Operational and Document Failures), the Plan Sponsor may include all such failures in a submission under Walk-in CAP.
Identification of failures. The VCR program is not based upon an exam- ination of the plan by the Service. The Service will not make any investigation or finding under the VCR program concern- ing whether there are Operational Fail- ures. Only the Operational Failures raised by the Plan Sponsor or Operational Failures identified by the Service in pro- cessing the application will be addressed under the program, and only those fail- ures will be covered by the program. However, because the VCR program does not arise out of an examination, consider- ation under the VCR program does not preclude or impede (under § 7605(b) or any administrative provisions adopted by the Service) a subsequent examination of the Plan Sponsor or the plan by the Ser- vice with respect to the taxable year (or years) involved with respect to matters that are outside the compliance statement. A Plan Sponsor’s statements describing Operational Failures are made only for purposes of the VCR program and will not be regarded by the Service as an ad- mission of a failure for purposes of any subsequent examination. If the plan fail- ures include failures correctable under VCR and failures correctable under Walk- in CAP, (e.g., interrelated Operational and Document Failures), the Plan Sponsor may include all such failures in a submis- sion under Walk-in CAP.
