The IRS’ Employee Plans office (EP) has often been a leader at creating program to encourage voluntary compliance—from the Administrative Procedure Regarding Self-Correction in 1991 to the modern Employee Plans Compliance Resolution System (EPCRS) to its significant customer education and outreach efforts. However, enforcement remains an important part of Employee Plans’ mission and focus.

With the adoption of the “cycle-based” determination letter program, enforcement staff who used to be shifted to determinations to handle the various filing spikes, such as the “GUST” deadline in 2002, are less likely to be temporarily assigned outside their enforcement roles. Further, over the past several years, the headcount in EP’s enforcement function has grown to represent a larger portion of EP’s staffing. And with new outreach tools, more and more plans are coming in contact with EP’s enforcement function.

In the attached article, the authors provide an overview of compliance and enforcement actions currently being undertaken by EP’s enforcement function.


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