I have a cafeteria plan covering several welfare benefit plans. Filing was never required since the number of participants in the component plans were less than 100 and a "Trust" was never established.
The plan sponsor is now closing the company so the plans will now be terminated. I read somewhere that even if fiing was never required, a final return must be filed for the cafeteria plan covering the welfare benefit plans.
Can anyone tell me if this is correct and if so, where can I find this information so I may show the client that we must file a final?