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Does A Plan Need It's Own TIN?


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Good morning everyone!  I'm getting a question from someone regarding getting a Plan it's own TIN.

I know for the EIN, generally we use the employers to file the Form 5500 with the IRS.  Is there a need to get each plan it's own individual TIN, however?  And if there are two plans (i.e. a 401(k) and a Cash Balance), would each Plan need it's own individual TIN?

Thanks in advance for your help!  I believe they are looking for a TIN in order to open the pooled account for the Profit Sharing and Cash Balance Plans (not a 401(k)).

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You would need a plan EIN for account ownership.

Also, if the plan writes distribution checks from those accounts and does withholding it has to have its own EIN for withholding deposits, 945s and 1099-Rs.

You can create a real mess if you deposit the withholding from a plan using the sponsor's EIN.    

The issue is you can find threads on here if you get a plan EIN and don't use it for a time the IRS will in effect declare the EIN no good. 

So this is a bit fact driven how important it is to get one. 

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The trust must have an EIN. Usually this comes up when you are opening a new account at a brokerage house, as they will need an EIN to open the account.

Even if you get a EIN for the plan, you must still use the sponsor's EIN on the 5500. The only place the trust EIN will appear on the 5500 would usually be on the Schedule R, and if you're talking about small plans you wouldn't usually need to attach a Schedule R.

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3 hours ago, C. B. Zeller said:

The only place the trust EIN will appear on the 5500 would usually be on the Schedule R, and if you're talking about small plans you wouldn't usually need to attach a Schedule R.

Small plans still may be required to issue Forms 1096, 1099-R, and 945, which will use the Trust EIN.

I'll also note that the proposed changes to Form 5500 includes a line for the Trust EIN, even though the 5500 itself uses the sponsor EIN. 

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