The AICPA said it has sent a letter to the Internal Revenue Service urging its agents to be aware of "scriveners' errors," or unintentional mistakes, in the drafting of employee benefit plans.
"As qualified plan regulations become increasingly complex, the potential increases for retaining unintended language and omitting the required information in qualified plans," wrote Jeffrey Hoops, chair of the AICPA's Tax Executive Committee.
He recommended that the IRS adopt a definition of scriveners' errors, establish methods to correct the resulting issues under the agency's Self-Correction Program and adopt a presumption that - absent evidence to the contrary - the sponsor intended to make no changes to policies and procedures when amending the plan documents to comply with changes in the law or a change in the plan document provider.
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