ATAT - Abusive Tax Avoidance Transaction
The IRS is engaged in extensive efforts to curb abusive tax shelter schemes and transactions. The Tax Exempt and Governmental Entities Division of the IRS, including the office of Employee Plans, participates in this IRS-wide effort by devoting substantial resources to the identification, analysis, and examination of abusive tax shelter schemes and promotions.
CAP - Closing Agreement Program
If a failure (other than a failure corrected through SCP or VCP) is identified on audit, the Plan Sponsor may correct the failure and pay a sanction. The sanction imposed will bear a reasonable relationship to the nature, extent, and severity of the failure, taking into account the extent to which correction occurred before audit. See our Correcting Plan Errors web page.
CIS - Case Identification Specialist
This person is responsible for identifying the EPTA universe of cases to be reviewed by the CSC as part of the case selection process.
CSC - Case Selection Committee
This committee is composed of three Area Managers, three EPTA Group Managers and the EPTA National Coordinator. The CSC uses a three-step process to select the cases that will be examined by the EPTA groups.
EO - Exempt Organizations
The office of Exempt Organizations ensures religious, charitable, social, educational, political and other not-for-profit organizations meet and maintain compliance with the complex requirements for tax-exempt status.
EP - Employee Plans
The office of Employee Plans serves the market of qualified pension benefit plans. Currently there are nearly one million plans that must file annual returns for group pension, profit sharing, 401(k), employee stock ownership (ESOP), and stock bonus plans. Simplified Employee Pensions (SEPs), SIMPLE plans, 403(b) tax-sheltered annuities, and IRC 457 government deferred compensation plans are generally not required to file returns.
EPCU - Employee Plans Compliance Unit
This is a newly established unit that will focus on data mining, emerging tax issues, EPCRS resolution compliance checks, funding deficiencies and non-filers.
EPCRS - Employee Plans Compliance Resolution System
EPCRS is a comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sections 401(a), 403(a) or 403(b) of the Internal Revenue Code, but which have not met these requirements for a period of time. See our Correcting Plan Errors web page.
EPTA - Employee Plans Team Audit
This is an audit involving some or all of the plans of a plan sponsor that warrants application of team examination procedures and is selected by the EPTA Case Selection Committee.
EPTA Team Coordinator
The Team Coordinator is a Team Member who, in addition to being responsible for a specific examination assignment, performs coordinating duties in planning and executing a team examination.
The EPTA Team consists of EPTA specialist(s), Computer Audit Specialist (CAS), actuary, attorney and other specialist/revenue agents working under the direction of the EPTA Case Manager.
ESOP - Employee Stock Ownership Plan
An ESOP is essentially a defined contribution plan whose funds must be invested primarily in employer securities. An ESOP may borrow from the employer or use the employer's credit to acquire employer securities.
GE - Government Entities
The office of Government Entities encompasses three distinct types of customers, Federal State and Local Governments (FSLG), Indian Tribal Governments (ITG) and Tax Exempt Bonds (TEB). Although not subject to Federal income tax, these governments are responsible for income tax withholding and paying employment taxes.
IDR - Information Document Request
The Information Document Request (Form 4564) is the form used by EPTA team members to request information and documentation from the plan sponsor.
IDRS - Information Document Retrieval System
The Information Document Retrieval System is an IRS system containing plan sponsor return information that can be accessed by IRS employees.
These transactions involve abusive tax avoidance transactions that must be disclosed pursuant to I.T. Regulation 1.6011-4. In addition, registration and record keeping rules are applicable to organizers and promoters of these transactions. Visit our EP Abusive Tax Transactions web page to review listed transactions applicable to EP.
LMSB - Large and Mid-Size Business Division
LMSB serves corporations, subchapter S corporations, and partnerships with assets greater than $10 million. These businesses employ a large number of employees, deal with complicated issues involving tax law and accounting principles, and conduct business in an expanding global environment.
MAP - Multi-Employer Plan
This is a plan established under a collective bargaining agreement that is maintained by two or more unrelated employers. These plans are commonly referred to as Taft-Hartley Plans.
NOPA - Notice of Proposed Adjustment
The NOPA (Form 5701) is used by the EPTA team to formally notify the plan sponsor of a proposed adjustment and/or plan failure.
EPTA Plan Sponsor
This refers to any entity sponsoring a pension plan or plans with an aggregate plan population of 2,500 or more. This would include multi-employer/multiple employer (MAP) and IRC section 403(b)/457 plans for which EPTA has examination responsibility.
Post Examination Critique
This consists of a meeting held among EPTA personnel and a separate meeting among EPTA and Plan Sponsor personnel to discuss the examination process and determine or identify opportunities for improvements.
This is the process involving a review of all returns, the planning file, commercial services, public records, etc. It is recorded in the form of a general outline of observations regarding size, dispersion, and diversification of the case, probable examination expertise and staffing requirements, and matters to be discussed or clarified at the pre-examination conference. When supplemented by information gained at the pre-examination conference it will form the basis for construction of the examination plan. It initially establishes the scope and depth of the examination.
SCP - Self-Correction Program
A Plan Sponsor that has established compliance practices and procedures may, at any time without paying any fee or sanction, correct insignificant Operational Failures. See our Correcting Plan Errors web page.
This refers to the specialists assigned to the case. Generally, they may be actuaries, commodity and financial products agents, engineers, excise tax agents, economists, international examiners, computer audit specialists, exempt organization agents, tax-exempt bonds agents, Indian tribal government specialists and any other revenue agent specialists who may be assigned to the EPTA Team.
TE/GE - Tax Exempt Government Entities
The Tax Exempt and Government Entities Division was established to improve the Service's ability to meet the special needs of pension plans, exempt organizations, and government entities in complying with the tax laws. TE/GE provides end-to-end service and accountability to its unique customer base. TE/GE's three major business units - Exempt Organizations (EO), Employee Plans (EP), and Government Entities (GE) - oversee a diverse range of customers, from small volunteer community organizations to sovereign Indian tribes to large pension funds. While these entities are not subject to Federal income tax, they nonetheless represent a significant aspect of tax administration.
VCP - Voluntary Compliance Program
A Plan Sponsor, at any time before audit, may pay a limited fee and receive the Service's approval for correction of a qualified plan, 403(b) plan, SEP or SIMPLE IRA plan. Under VCP, there are special procedures for anonymous submissions and group submissions. See our Correcting Plan Errors web page.