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Employee Plans Compliance Unit (EPCU) - Current Projects - Partnership Investment Project

Why did I receive an EPCU Compliance Check Letter?

Our records indicate your plan invests in a partnership.

A retirement plan may purchase a partnership interest as a plan investment. However, a plan that invests in a partnership must follow all applicable rules relating to prohibited transactions, unrelated business income and the valuation of plan assets. This project will assess the compliance with these rules as they relate to plans that own partnership interests.

What is the EPCU attempting to determine?

The compliance check letter and information request asks for information to assist us in answering these questions:

  • Was the partnership interest properly valued?
  • Did the partnership generate any unrelated business income tax for the plan?
  • When necessary, was a Form 990-T filed and tax paid for all unrelated business income tax?
  • Did the investment in the partnership result in a prohibited transaction?
  • When necessary, was a Form 5330 filed and all excise tax paid for all prohibited transactions?

What actions do I need to take?

Please complete the information request. You may also furnish any other documents or clarifying material that you believe will be helpful for us to review. You should make every effort to be as complete and accurate as possible in your responses and respond by the due date.

What if I need more time to respond? What if I do not respond at all?

If you need additional time, make sure to contact the EPCU representative (located on the letter) to request an extension. Failure to provide the information could result in further action or examination of your plan.

If There Are Any Questions

Please feel free to e-mail us and we will be glad to answer any questions you have about the project. Please include "Partnership Project" in the Subject line.

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Page Last Reviewed or Updated: 11-Oct-2016