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If no Employees have ever been auto-enrolled, what's the rush to remove it? I agree it seems allowable, but why not wait until year end to do so?

Also, a 1-participant plan with assets under $250,000 isn't required to file. Going back that far, it used to be a lower threshold for filing, but I don't recall off-hand when it changed. If they were required to file a 5500 for 5500-SF and did not, the filing fee for the delinquent filer program for 27 filings is the same as for 2 filings. If the forms were prepared each year and just not filed, I would be inclined to file all of the late ones under the program, just to be safe. Even if they were not prepared at the time, the fees to get the forms done if you have good records should be much less than the potential late filing penalties.

The normal due date means the last day of the 7th month after the end of plan year whether it is short or not. So for the short plan year, the extended due date will be 9 1/2 months after the end of the short plan year.

If you think any have EVER been filed, get a 2848 signed by the client and call the IRS to ask them if they have record of any EVER having been filed. It may take a while on hold and then you will be asked to fax the 2848 while on the phone, but they are very helpful.

They just did not explain what they meant at all. Shocking because the IRS never makes consequential statements that leave us nuts and bolts people wondering how the heck we actually implement things.