Sponsoring and administering an employee benefit plan requires that you deal with the IRS. Whether you need a letter ruling on a technical issue, approval of a plan correction under EPCRS, or representation on an employee plans audit, you want skilled counsel at your side who know the key policymakers at the IRS.
At Caplin & Drysdale, we constantly represent clients before the IRS in the most difficult employee benefits matters. Our lawyers have significant experience working with key personnel at the IRS, both in government service and in private practice.
Representative Engagements
The IRS representation we provide for our clients almost always involves highly sensitive benefits matters - often affecting millions or even billions of dollars of retirement-plan assets. We have:
- Represented clients on letter rulings and technical advice memoranda presenting novel legal questions, sometimes affecting entire industries
- Negotiated closing agreements in audits involving qualification issues for extremely large qualified plans
- Obtained favorable resolution of numerous technical issues on behalf of our clients in all facets of EPCRS
Our Services
Representation at the IRS, both in the national office and in the field:
- Preparation of letter ruling requests and technical advice requests
- Representation before the IRS on EPCRS matters, including VCR, Walk-in CAP, TVC, and Audit CAP
- Representation in IRS employee plans examinations
- Negotiation of closing agreements
- Litigating disputes
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