If you send the IRS a Voluntary Compliance Program (VCP) submission on paper on April 1, it will be returned to you. But it won’t be an April Fools Day joke.
Beginning April 1, 2019, the IRS will only accept VCP submissions that are made electronically through Pay.gov. It will return VCP submissions made on paper that have a postmark after March 31, 2019. The IRS has been accepting applications and payments under the VCP program since January. The switch to e-filing was announced last September in Rev. Proc. 2018-52.
The IRS has provided the following tips concerning electronic VCP submissions:
- Applicants should include all required VCP submission items in the PDF file they upload to the IRS. They should place the VCP submission documents in the uploaded PDF in the order specified by Section 11.11 of Revenue Procedure (Rev. Proc.) 2018-52.
- Section 11.04 of Rev. Proc. 2018-52 provides more information, as well as enclosure lists associated with the model Form in the Form 14568-A through Form 14568-I series.
- Since the completed Form 8950 is uploaded automatically, there is no need to include a copy of Form 8950 as part of the uploaded PDF file containing the VCP submission documents.
- A VCP application is not considered to be filed with the IRS until the VCP user fee has been paid and the Pay.gov website generates a payment confirmation receipt. Applicants that do not have a receipt with a Pay.gov Tracking ID # have not made a VCP submission to the IRS.
The IRS suggests reviewing the electronic VCP submission process outlined in Rev. 2018-52, and the updated Retirement Plan Correction Procedures that discuss the VCP submission process before making a VCP submission. Additional information is available in this IRS video.
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