Form 8950 - Application For Voluntary Correction Program (Vcp) Page 5
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65
Form 8950 (Rev. 11-2017)
Page
Procedural Requirements Checklist (Continued)
12 Have you included a detailed description of the method for correcting the failures that the plan sponsor has implemented or
proposes to implement to correct each failure described in this VCP submission? Each step of the correction method must
be described in narrative form and must include specific information needed to support the proposed correction method.
See the current EPCRS revenue procedure in effect at the time the submission is made to the IRS.
13 Have you included a description of the administrative measures that have been or will be implemented to ensure that each
qualification failure described in this VCP submission does not recur? See the current EPCRS revenue procedure in effect
at the time the submission is made to the IRS.
14 For each failure involving corrective contributions or distributions, have you included an explanation that provides a detailed
narrative explaining the methodology you have used to determine lost earnings and how this is consistent with EPCRS
correction principles? See the current EPCRS revenue procedure in effect at the time the submission is made to the IRS.
15 For each failure involving corrective contributions or distributions, have you included detailed and specific calculations for
each affected employee or a representative sample of affected employees? The sample calculations must be sufficient to
demonstrate each aspect of the proposed correction method. See the current EPCRS revenue procedure in effect at the
time the submission is made to the IRS.
16 For each failure involving participant loans that does not comply with section 72(p) requirements, have you included:
• An explanation that contains a detailed description of the failure;
• An explanation that requests income tax reporting relief, and/or a request to report the distribution on Form 1099-R in
the year of correction instead of the year of failure;
• For each case in which income tax reporting relief has been requested, detailed calculations and narrative that describe
the correction proposal and demonstrate compliance with the requirements set forth in the current EPCRS revenue
procedure in effect at the time the submission is made to the IRS?
17 For each operational failure that has resulted in certain excise taxes, have you included a request and supporting
explanation asking the IRS to waive or not pursue excise tax under section 4972, 4973, 4974, or 4979 or additional income
tax under section 72(t), as applicable? Where required, have you included detailed explanations supporting the request?
See the current EPCRS revenue procedure in effect at the time the submission is made to the IRS for information as to
when such waivers are available.
18 Have you included an explanation that describes the method(s) used to locate and notify former employees or
beneficiaries? If there are no former employees or beneficiaries affected by the failure described in this VCP submission or
the proposed method of correction, have you provided an affirmative statement to that effect? See the current EPCRS
revenue procedure in effect at the time the submission is made to the IRS.
19 For each failure described in this VCP submission that includes a failure related to transferred assets, as defined in the
current EPCRS revenue procedure, have you included an attachment that describes the related employer transaction,
including the date of the employer transaction and the date the assets were transferred to the plan? See the current EPCRS
revenue procedure in effect at the time the submission is made to the IRS.
20 For operational failures, have you included a copy of the plan document (and adoption agreement, if applicable) or
applicable provisions of the plan document, that were in effect during the period of failure? See the current EPCRS revenue
procedure in effect at the time the submission is made to the IRS.
8950
Form
(Rev. 11-2017)
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