austin3515 Posted September 10, 2018 Share Posted September 10, 2018 Code C Purpose: "Use this code for a participant previously reported under the plan of a different plan sponsor and who will now be receiving a future benefit from the plan reported on this form. Also complete columns (b), (c), (h), and (i)." So a client is merging Plan A into Plan B. Plan A happened to be an employee contribution only and Plan B happened to be Employer contributions only. Both are sponsored by the same plan sponsor. Based on the instructions above, I am planning on NOT reporting these folks as a Code C on the surviving plan. Do we all agree? Austin Powers, CPA, QPA, ERPA Link to comment Share on other sites More sharing options...
david rigby Posted September 10, 2018 Share Posted September 10, 2018 No matter the original source of contributions, isn't the payment "from the plan"? I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice. Link to comment Share on other sites More sharing options...
austin3515 Posted September 10, 2018 Author Share Posted September 10, 2018 I don;t follow you. Am I misreading the instruction? If so, how? I don;t see any reference to which plan will pay the benefit? Austin Powers, CPA, QPA, ERPA Link to comment Share on other sites More sharing options...
austin3515 Posted September 10, 2018 Author Share Posted September 10, 2018 Ahh, ok, I see "will now be receiving future benefits from this plan" BUT the first word before that phrase is AND. And it's not a different sponsor so it doesn;t apply? Austin Powers, CPA, QPA, ERPA Link to comment Share on other sites More sharing options...
RatherBeGolfing Posted September 10, 2018 Share Posted September 10, 2018 1 hour ago, austin3515 said: Ahh, ok, I see "will now be receiving future benefits from this plan" BUT the first word before that phrase is AND. And it's not a different sponsor so it doesn;t apply? I'm not so sure that is correct, but the wording in the instructions contradict the wording on the Form 8955-SSA itself so it isn't 100% clear. The Form itself says "Code C — has previously been reported under another plan, but who will be receiving benefits from the plan listed above instead." To limit it to a plan of another sponsor doesn't make much sense since the 8955 is plan specific. Code C simply signals to SSA to transfer the previously reported benefit (a P with code A in prior years) to a new plan so that they can reference the correct plan when they send their "you may have a benefit" letter out. If the balance of a participant who has been a code A in the past is going to be paid out from plan 002 rather than 001, the participant should be a code C for 002 and a code D for 001. So no need to use code C for anyone who was not a code A in the past. Link to comment Share on other sites More sharing options...
austin3515 Posted September 10, 2018 Author Share Posted September 10, 2018 OK you talked me into it. I don;t know why but I hate doing them :) Austin Powers, CPA, QPA, ERPA Link to comment Share on other sites More sharing options...
Calavera Posted September 12, 2018 Share Posted September 12, 2018 Do not forget to report all terminated people reported previously, with code D under plan A. Link to comment Share on other sites More sharing options...
austin3515 Posted September 12, 2018 Author Share Posted September 12, 2018 You're joking, right? I have to D them and C them? Shouldn't one take care of both? Austin Powers, CPA, QPA, ERPA Link to comment Share on other sites More sharing options...
RatherBeGolfing Posted September 12, 2018 Share Posted September 12, 2018 44 minutes ago, austin3515 said: Shouldn't one take care of both? No, you have to remove them with a D in the original plan and add them with a C in the second plan Link to comment Share on other sites More sharing options...
austin3515 Posted September 12, 2018 Author Share Posted September 12, 2018 Who come sup with these rules??? :) OK, I'll do it... Austin Powers, CPA, QPA, ERPA Link to comment Share on other sites More sharing options...
RatherBeGolfing Posted September 12, 2018 Share Posted September 12, 2018 The worst part is that SSA will probably still screw up and send out a "you may have some $$$" letter for each plan.... K2retire 1 Link to comment Share on other sites More sharing options...
Calavera Posted September 13, 2018 Share Posted September 13, 2018 19 hours ago, austin3515 said: You're joking, right? I wish. See below (emphasis mine) Code D - Use this code for a participant previously reported under the plan number shown on this form who is no longer entitled to those deferred vested benefits. This includes a participant who has begun receiving benefits, has received a lump-sum payout, or has been transferred to another plan (for example, in the case of a plan termination). Also complete columns (b) and (c). Participants should not be reported under Code D merely because they return to the service of the plan sponsor. Link to comment Share on other sites More sharing options...
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