Yes, the IRS can audit plans for which an election is made under ERISA Section 1022(i)(2). In addition, IRS can audit plans with trusts sited in the U.S. and covering Puerto Rican employees, generally referred to as dual-qualified plans. These plans must qualify under both the Puerto Rico Code and the Internal Revenue Code. The IRS would obtain compliance-related information on these plans either by conducting its normal audit activities with prior coordination with Hacienda or by requesting Hacienda to obtain the needed information. The IRS can also audit Puerto Rico-only qualified plans claiming exempt status under Internal Revenue Code Section 501(a).