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Short Plan Year Due to Termination


Vlad401k

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Probably a very simple question here, but I couldn't find too much guidance on the IRS site. If the plan was terminated in 2014 and all the distributions were done by, let's say September 10th, should the ending date on the Form 5500 be reported as 9/10/2014 or should it be the end of the month in which the distributions happened, so 9/30/2014? The end result is the same as the filing is due 7 months after the month of last distribution. Just wanted to see if there's a requirement to do it one way or the other.

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I agree you get the same due date but I think the Form 5500 instructions in fact do answer your question.

http://www.dol.gov/ebsa/pdf/2014-5500inst.pdf

Section 2 says:

For purposes of this return/report, the short plan year ends on the date of the change in accounting period or upon the complete distribution of assets of the plan.

So I read that as saying 9/10/2014.

It would seem like if the plan is audited that is when the auditor would date his report as there is nothing to audit beyond that date.

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