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Frozen DB Plan - Line 13p on Form 5310

Guest Eric A

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Guest Eric A

I have a question on completing the IRS Form 5310 for a terminating DB plan that was previously frozen.

Lines 13 and 14 of the 5310 ask for information regarding coverage and nondiscrimination for the year of termination. Line 13 states that you need to complete only line 13p if the plan satisfied coverage using the requirement of 1.410(b)-2(b)(6) (no HCEs benefit). The 5310 also states that if line 13p is completed, skip line 14.

For this plan, no HCE is treated as benefiting under the plan for the year of termination due to the plan freeze. Is there any reason I can’t just complete line 13p of the 5310 on the basis that no HCEs benefit and skip the rest of line 13 and all of 14? It seems to me that I can complete the form this way, but others I’ve spoke to disagree.

All thoughts and/or comments are appreciated. Thanks.

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