The IRS recently had an issue with their programming system which resulted in CP 283-C penalty notices mistakenly being sent out on timely filed Forms 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits. The IRS provided a bulletin on Sept. 1, 2023, which provided the following information:
- If the penalty notice the employee benefit plan/plan sponsor/plan administrator received is dated before Sept. 1, 2023, no response is necessary if the plan has timely filed a complete return.
- The IRS has resolved the programming issue and will be updating records to reflect timely and complete filings.
- The IRS also reminds employee benefit plan sponsors to ensure the Form 8955-SSA is filed with the IRS and not through the DOL EFAST2 System.
What does CohnReznick think?
We believe that recipients of such notices predating Sept. 1, 2023, should be able to take no action, provided they have either (1) proof of timely filing of a Form 8955-SSA, or (2) proof of timely filing of an extension application for the Form 8955-SSA.
If you received a notice, we recommend that you:
- Keep the notice for your records
- Keep a copy of the bulletin
- Monitor future IRS correspondence to help ensure no future notices
- Ensure the plan files Form 8955-SSA with the IRS and not through the DOL EFAST2 System
Zachary Segal, CPA, Senior Manager, Exempt Organizations Tax Services
CohnReznick Tax: Alerts and Webinars
Subject matter expertise
CPA, MST, Partner & Exempt Organizations Tax Services Leader
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Any advice contained in this communication, including attachments and enclosures, is not intended as a thorough, in-depth analysis of specific issues. Nor is it sufficient to avoid tax-related penalties. This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice specific to, among other things, your individual facts, circumstances and jurisdiction. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.