Editorial Standards
How we research, review, and update this guide
Every Accountably guide is researched against primary IRS sources, reviewed by a U.S. CPA, and refreshed as guidance evolves. Read our Editorial Guidelines to see how we source, fact-check, and update our content.
That is the gap Accountably fills. We are a U.S. accounting and tax outsourcing & offshoring services company that delivers production capacity without chaos. We build disciplined offshore delivery, so you can hit deadlines, protect quality, and keep your advisory pipeline moving.
The bottleneck is delivery, not demand. When production is disciplined, growth stops being scary and starts being repeatable.
Key Takeaways
- Form 8717 is the User Fee for Employee Plan Determination Letter Request (Rev. June 2022, OMB No. 1545-1772, Cat. No. 64727O). Section 7528 authorizes the IRS to charge the user fee.
- It is submitted with the underlying determination letter application. Starting July 1, 2022, Pay.gov is required for Form 5300 submissions and the applicable user fees.
- An eligible employer under section 408(p)(2)(C)(i)(l) is one that had no more than 100 employees who each received at least $5,000 of compensation for the preceding year, and that has at least one participant who is not a highly compensated employee (section 414(q)).
- The user fee exemption under section 7528(b)(2)(B) applies to eligible employers that request a determination letter within the first 5 plan years.
- Under the 10-year rule, the IRS treats an application as filed within a qualifying open remedial amendment period if the plan was first in existence no earlier than January 1 of the 10th calendar year preceding the year the application is filed.
Why delivery becomes the ceiling as you grow
Partners can sell. Pipelines are healthy. Yet deadlines slip, reviews pile up, and teams burn out. Most firms do not struggle because of a lack of clients, they struggle because delivery breaks once growth accelerates. Common barriers we see when we audit a new client’s workflow:
- Capacity spikes around peak season, then idle valleys that make hiring feel risky.
- Partner and senior time trapped in review loops instead of advisory and client strategy.
- Hiring delays and turnover that create permanent resourcing gaps.
- Rising salaries and overhead making expansion feel expensive and fragile.
- Inconsistent work quality across preparers and reviewers, which forces rework.
- Limited workflow visibility, weak documentation, and unclear accountability.
- Missed deadlines that wear down client trust and limit referrals.
- Complex multi‑entity, multi‑state footprints that strain process control.
- Rushed workpapers that slow reviews and mask avoidable errors.
- Compliance fatigue as IRS and state updates stack up in the background.
- Advisory stuck on the runway because production buries the team.
This is not a sales problem, it is a delivery system problem. If the system cannot deliver, growth hits a ceiling.
Why most offshore attempts fail
Firms often try offshore as a quick capacity fix. It rarely sticks when treated like staffing. Typical failure patterns:
- No clear SOPs, so work varies by person and week.
- Workpapers are unstructured, poorly named, and hard to review.
- Review expectations are fuzzy, so revisions balloon.
- Missing schedules and weak documentation discipline.
- No SLAs or delivery metrics, so turnaround is unpredictable.
- Vendors send resumes, not accountable teams with managers.
- No layered quality control, so errors slip to partner review.
- Gaps in U.S. GAAP, IRS standards, and firm communication norms.
- Reactive communication, not workflow‑driven updates.
- Loose access controls, a security headache waiting to happen.
- Dependency on freelancers with no continuity plan.
Capacity without structure creates noise, not relief.
How Accountably fixes the delivery problem
Accountably is not a staffing vendor. We design and run a controlled offshore delivery system for teams that cannot trade quality or security for speed. Our U.S.‑led team embeds into your workflow with a delivery architecture built for speed, review protection, and accountability.
Structured onboarding for U.S. accounting and tax standards
Every professional we deploy is trained on U.S. accounting work, IRS workflows, and firm communication. We put each new teammate through a three‑week delivery readiness framework that covers review note etiquette, documentation logic, and deadline accountability. They work in your systems, your templates, and your client expectations from day one.
Our teams work inside QuickBooks, Xero, UltraTax, CCH Axcess, ProConnect, Lacerte, Drake, Thomson Reuters, Canopy, Karbon, TaxDome, Suralink, and JetPack. We align to your naming rules, folder logic, and checklists.
Delivery structure that protects quality and time
- SOP‑driven execution across bookkeeping, month‑end close, tax, and year‑end support.
- Structured workpapers with standardized naming and version control.
- Multi‑layer review, preparer to senior to quality to final, so partner review is lighter.
- Turnaround SLAs by engagement type and complexity.
- Internal pre‑review checklists to reduce back‑and‑forth.
- Live workflow tracking with escalation rules for early issue flags.
- Capacity planning based on utilization data, not guesswork.
- Continuity plans if a team member is out, delivery does not stop.
You get fewer revision cycles, faster partner sign‑off, and less delivery friction.
IRS Form 8717 made simple for busy plan practitioners
If you handle qualified plan work, you know Form 8717 sits at the doorway of an employee plan determination letter request. Here is the part that trips teams up. For modern e‑filed applications, you no longer attach Form 8717 with a check. You pay the user fee inside the Pay.gov application, then use Form 8717 only when an additional payment is required. The Pay.gov form itself spells this out and even provides a specialist contact for payment confirmations.
What Form 8717 does today
- It documents the user fee tied to determination letter applications for plans and group trusts.
- For e‑filed Forms 5310, 5300, 5307, and 5316, the user fee is paid within Pay.gov, not via a paper Form 8717. Use Form 8717 on Pay.gov only if you need to send an additional payment.
- The current IRS page and the form PDF confirm the role shift, and they direct filers to the online fee schedule and the annual revenue procedure for the exact amounts.
Practical rule, if the application is on Pay.gov, the user fee is on Pay.gov. Form 8717 comes back into play only when you need to true up.
How Accountably handles Form 8717 for your firm
- We set up a clean Playbook for EP determinations, including Pay.gov owner, backup owner, and a submission checklist.
- We pre‑stage your fee category, confirm the current amount from the IRS user fee schedule, and capture the Pay.gov confirmation page for your files.
- For additional payments, we submit via the Form 8717 page on Pay.gov, then send the confirmation to the assigned Employee Plans Specialist, exactly as instructed.
- We keep your evidence trail tight, so matching to the case is fast, and reviews are shorter.
Who must pay, and when the small‑employer exemption applies
Most applicants must pay a user fee with each determination letter request. The small‑employer exemption remains in effect, and it is underused. You qualify if all of the following are true:
- You have 100 or fewer employees who each received $5,000+ in the calendar year before you file.
- You have at least one participating employee who is not highly compensated under section 414(q).
- You file by the last day of the fifth plan year the plan is in existence, or by the end of a remedial amendment period that begins within those first five years. IRS guidance also treats certain later filings as timely under the ten‑year rule in Notice 2017‑1 (the plan must have been first in existence no earlier than January 1 of the 10th calendar year preceding the year you file, not a rolling 10‑year anniversary from plan adoption).
If you qualify, complete only the certification on Form 8717 and leave the fee section blank (and if you fall outside the 10‑year safe harbor but still meet the section 7528(b)(2)(B) requirements, attach a cover letter explaining how the exemption is satisfied, the cover letter is mandatory in that case). Your package will be returned if you claim the exemption without actually meeting the criteria, so document your headcount, compensation, participation, and timing.
Documentation we set up for you
- Headcount and compensation proof for the prior calendar year, payroll reports, and sampling notes.
- Proof of at least one non‑HCE participant and the plan’s effective date history.
- A timing tracker that maps the first five plan years and any remedial amendment periods.
- A signed certification and a filing binder ready for future IRS requests.
Electronic payments, Pay.gov accounts, and guest access
Pay.gov accepts ACH and card. You can preview the form as a guest, then sign in to submit. An account lets you view prior payments, store methods, and copy previous forms, which speeds repeat filings. The Pay.gov form explains both flows clearly.
Additional payments and specialist notifications
If you submit an additional payment through the Form 8717 page on Pay.gov, retain the confirmation and send it to the Employee Plans Specialist assigned to your case, as the form directs. The Pay.gov page provides a contact name and phone for assistance.
What we do so you do not have to
- Validate the correct fee category against the latest revenue procedure and IRS fee page.
- Submit payment through Pay.gov, capture confirmations, and notify the specialist with the exact identifiers the IRS requests.
- Store receipts and bank records in your DMS with consistent naming, so audits and reviews are quick.
Filing logistics and addresses you can trust today
Paper is the exception now, however when you need to mail something for EP determinations, use the current IRS addresses. The IRS updated EP mailing addresses to a Covington P.O. Box for USPS and a Florence, Kentucky street address for private delivery. The current Form 8717 PDF and the IRS address notice align.
Where to send EP determination items
| Method | Address |
| USPS | Internal Revenue Service, Attn: EP Determination Letters, Stop 31A Team 105, P.O. Box 12192, Covington, KY 41012‑0192 |
| Private delivery | Internal Revenue Service, Attn: EP Determination Letters, Stop 31A Team 105, 7940 Kentucky Drive, Florence, KY 41042 |
Always check the latest IRS page before shipping, since addresses do change.
E‑file requirements that catch teams off guard
- Form 5310 applications filed on or after August 1, 2021 require Pay.gov e‑file with user fee paid in‑flow.
- Form 5300 applications filed on or after July 1, 2022 require Pay.gov e‑file with user fee paid in‑flow.
- Forms 5307 and 5316 filed on or after July 1, 2023 require Pay.gov e‑file with user fee paid in‑flow. For these forms, use the standalone Form 8717 on Pay.gov only when making an additional payment.
The IRS Internal Revenue Manual also reflects the Pay.gov rule, which is why our teams treat Pay.gov as the default for these applications.
Quick clarifications about Form 8717 line 5 and coverage
Older internal notes in some firms say line 5 selections on Form 8717 control coverage testing review and the fee. The current form is simpler. Line 5 is where you check the applicable application type and enter the fee amount (skip the shaded gray subitems under lines 5g and 5h, those are marked Reserved and are no longer functional). Coverage and testing elections live inside the determination letter application itself, including any required attachments or demonstrations for your plan’s testing method. The form PDF and the IRS pages now point you to the online fee schedule and current revenue procedure for exact amounts.
Treat line 5 as a fee entry step, not a place to manage your coverage testing scope.
Security, compliance, and work integrity with Accountably
When you let a partner inside your workflow, trust matters more than anything. Accountably runs with structured safeguards that protect client data while keeping delivery efficient.
- SOC 2 aligned controls and NDA‑backed confidentiality.
- Role‑based data access, zero local storage, encrypted file exchange.
- Secure VPN, server protection, and audit logs for activity records.
- Background‑verified staff and U.S. client data integrity standards.
- Documentation discipline that supports audit and IRS requests.
Compliance foundations you can rely on
- U.S. GAAP aligned accounting practices.
- IRS and state tax standards, multi‑state payroll familiarity, and sales tax workflows.
- Documentation and audit support readiness that shortens review time and reduces back‑and‑forth.
With this baseline, your team gets predictability and a cleaner review experience, and your clients get on‑time delivery without drama.
Engagement models that scale with you
Accountably meets you where you are, then grows with your pipeline.
Options that give you control
| Model | Best for | Value |
| Dedicated Offshore Talent | Teams that need stable production capacity across close, compliance, and cleanup | Full‑time accountants and tax staff who live inside your workflow and tools |
| White‑Label Delivery Teams | Teams scaling seasonal workload or specific compliance lines | End‑to‑end pods that include preparers, seniors, and reviewers managed to SLAs |
| Build–Operate–Transfer (BOT) Offshore Unit | Teams that want their own long‑term offshore center | We build and run your center, then transfer it when you are ready, with continuity baked in |
No short‑term band‑aids, no resume farming, just dependable offshore execution guided by your standards.
Work we support across accounting, taxation, advisory, and audit support
We cover the core work that eats your calendar, plus the documentation and review guardrails that protect your partners’ time.
Accounting execution
- Month‑end close and reconciliations, AP, AR, cleanup, and multi‑entity consolidation.
- Financial reporting packages, fixed asset schedules, depreciation, and GL adjustments.
- Cash flow statements and controller‑level support.
U.S. taxation, including EP determination support
- 1040, 1120, 1120‑S, 1065, and 990 preparation, cleanup, and review support.
- SALT, year‑end processing, workpaper preparation that shortens reviews.
- Employee Plans determination letter support, including Form 5300, 5307, 5310, 5316 e‑file steps, user fee validation, and additional payments through Form 8717 on Pay.gov with specialist notification.
Client accounting services and payroll
- Monthly financial packages, payroll review, and T&E allocations.
- Client onboarding and cleanup with tight documentation for transitions.
Advisory and audit support
- Management reporting, KPI packs, and board‑ready decks.
- Prepared‑by‑Client coordination, schedules, and evidence packs for auditors.
- Pre‑audit file hygiene, tie‑outs, and request tracking that keep your team out of firefighting.
What‑How‑Wow for Form 8717 and EP determinations
- What, firms must pay a user fee for employee plan determination letter applications, with a small‑employer exemption when criteria are met. The fee and payment method depend on the form and filing date.
- How, for e‑filed Forms 5310, 5300, 5307, and 5316, you pay inside Pay.gov and use Form 8717 only for additional payments, then send the confirmation to your assigned specialist. We run the checklist and evidence trail for you.
- Wow, fewer corrections, shorter reviews, and clean documentation that stands up to scrutiny. Your partners get hours back every week in peak season.
Common Mistakes We See Every Season
Across plan-determination engagements, the same Form 8717 mistakes return year after year. Most are routing errors, not technical ones, and each one delays the underlying 5300, 5310, 5307, or 5316 by weeks.
Reusable Checklists
Below are three copy-paste-ready checklists that drop straight into a firm SOP. Each one ties to a specific failure mode the Form 8717 (June 2022) instructions warn about.
Pre-file packet (Form 8717 + underlying application)
- Confirm the underlying application form: 5300, 5307, 5310, 5310-A, or 5316.
- Look up the current user fee in Appendix A of the latest annual Rev. Proc. (Rev. Proc. 2022-4 or its annual successor); do not rely on amounts printed in older copies of Form 8717.
- Verify lines 1-4: sponsor name, EIN, plan number, plan name.
- Enter the fee on the active line only (5a, 5b, 5c, 5e, 5f, or 5i). Skip lines 5g and 5h – they are shaded Reserved and not functional.
- For Form 5300 and Form 5310 fees, complete the Pay.gov payment and print the confirmation page for the packet.
- If paying by check (insufficient-fee top-up or another active line), make it payable to "United States Treasury" and attach to the left side of Form 8717.
- One Form 8717 per plan; never combine multiple plans on a single transmittal.
- Mailing label: Internal Revenue Service, Attn: EP Determination Letters, Stop 31A Team 105, P.O. Box 12192, Covington, KY 41012-0192. Never the Washington, DC address on the form.
Small-employer exemption test (IRC 7528(b)(2)(B))
- Headcount: confirm the employer had no more than 100 employees who received at least $5,000 of compensation in the preceding year.
- Non-HCE participation: confirm at least one non-highly-compensated employee (per IRC 414(q)) actively participates in the plan.
- Timing prong: the request is filed within the first 5 plan years OR by the end of a remedial amendment period that began in those first 5 years.
- 10-year safe harbor: the plan was first in existence no earlier than January 1 of the 10th calendar year preceding the filing year (per the IRS instruction example: an application filed in 2017 covers plans first in existence on or after January 1, 2007).
- Determination date: apply all three prongs as of the date the request is filed; not plan-year start, not prior 12/31.
- If exempt: complete only the Certification block and leave line 5 blank.
- If outside the 10-year safe harbor but still qualifying under 7528(b)(2)(B): attach a cover letter walking through the remedial amendment period and the exemption qualification.
Pay.gov handoff (Form 5300 and Form 5310)
- Confirm Pay.gov is the required channel: mandatory for Form 5300 user fees since July 1, 2022 and for Form 5310 since the form revision.
- Complete the Pay.gov payment under the sponsor account or as a guest, using the current Rev. Proc. user fee schedule for the amount.
- Save and print the Pay.gov confirmation page; it must travel with the application packet.
- Cross-check the Pay.gov amount against Appendix A of the current Rev. Proc. user fee schedule to avoid an insufficient-fee return.
- If the IRS notifies you the fee was short, file Form 8717 as the top-up vehicle for the difference (the one remaining 5300/5310 use case for Form 8717 with a check).
- Retain the Pay.gov confirmation and Form 8717 copy in the engagement file; the Paperwork Reduction Act notice on Form 8717 requires that books or records relating to the form be retained as long as their contents may be material in administering any Internal Revenue law.
Keep 8717 Season From Stalling
Determination letter work hits firms in waves. Whenever a sponsor terminates a defined contribution plan, adopts a modified volume submitter, or amends a group trust, the user fee packet (Form 8717 plus the underlying 5300, 5307, 5310, 5310-A, or 5316) has to leave the office clean the first time. The IRS estimates recordkeeping alone takes 1 hour 40 minutes per filing (per the Paperwork Reduction Act notice on Form 8717), and a returned packet for the wrong payee, the wrong address, or an insufficient fee pushes the whole engagement back weeks.
Almost all of that rework is preventable. The user fee schedule is published annually in Appendix A of the current Rev. Proc. (Rev. Proc. 2022-4 and its annual successors, per the Form 8717 instructions), Pay.gov is now the only acceptable channel for the underlying 5300 and 5310 user fees, and the eligible-employer test has a hard three-prong checklist behind it. Build the controls into the SOP once and they run themselves.
- Pin the fee lookup to a single source: Appendix A of the latest annual Rev. Proc. or the IRS user-fees page. Never quote amounts printed in older copies of Form 8717.
- Move every Form 5300 and Form 5310 user fee through Pay.gov, print the confirmation, and keep Form 8717 in the packet only for insufficient-fee top-ups.
- Run the eligible-employer test as of the filing date (not plan-year start) and document all three prongs: 100-employee/$5,000 headcount, at least one non-HCE participating, and the 5-year or remedial amendment period window.
- Use the 10-year safe harbor as a calendar check (plans first in existence no earlier than January 1 of the 10th preceding calendar year) and attach a cover letter whenever the application falls outside it but still qualifies under 7528(b)(2)(B).
- Lock the mailing label: Internal Revenue Service, Attn: EP Determination Letters, Stop 31A Team 105, P.O. Box 12192, Covington, KY 41012-0192 for U.S. mail, or 7940 Kentucky Drive, Florence, KY 41042 for Express Mail. Never the Washington, DC Tax Forms and Publications address.
Built into a standing playbook, Form 8717 turns from a recurring inbox fire into a fifteen-minute desk check. Our offshore tax delivery team runs the fee lookup, the eligible-employer test, and the Pay.gov confirmation step as part of every determination letter packet, so the underlying 5300 or 5310 leaves the office complete the first time.
FAQs
Do I still attach a paper Form 8717 with a check?
Not for the modern e‑filed applications listed by the IRS. For Forms 5310, 5300, 5307, and 5316 on or after their Pay.gov effective dates, you pay the fee as part of the Pay.gov application and use Form 8717 only to make an additional payment if the IRS requests it.
How do I claim the small‑employer exemption?
Confirm that you have 100 or fewer employees with $5,000+ compensation in the preceding calendar year, at least one non‑HCE participant, and that you are within the timing window. Then complete only the certification on Form 8717. Keep documentation in your file, since the IRS can ask for verification.
What are the current fees?
The IRS updates user fees through its annual revenue procedure and the online fee schedule. We confirm the amount each time before filing and store proof in your case file.
Where do I send paper items if needed?
Use the IRS Covington P.O. Box for USPS and the Florence, KY street address for private delivery, as currently posted by the IRS and reflected on Form 8717. Verify before shipping.
Who do I notify after an additional payment?
Send the Pay.gov confirmation to the assigned Employee Plans Specialist on your case. The Pay.gov Form 8717 page provides a help contact if you need assistance coordinating the match.