These are probably a silly questions, but with such an astronomical penalty, I want to ensure I get this right.
1. Box 1A. reads "This return is: (1) the first return filed for the plan (2) an amended return (3) the final return filed for the plan (4) a short plan year return (less than 12 months)"
For each return, would "(1)the first return filed for the plan" be checked, or does this mean only for the very first return? I.e., does this mean for the plan year being filed, or ever? It sounds like this would only apply to the very first year being filed, but on the form, it looks like this should be checked each year, since this is not an amended return or final return. The instructions say "First Return Check box A(1) if this is the first filing for this plan. Do not check this box if you have ever filed for this plan, even if it was a different form (for example, Form 5500)." But lets say, for example, I file 2021 as the first plan year, and now I'm filling out 2022. I guess another way to ask this question, is it ok to leave Box A blank?
2. When submitting the late return, if box D is available, do I still need to write in red “Delinquent Return Filed under Rev. Proc. 2015-32, Eligible for Penalty Relief” at the top of the return?
3. If I'm sending these in now, in March, would it be prudent to wait until closer to the July 31 deadline to file for the last plan year electronically, which is not currently delinquent, to avoid triggering a notice for the previous years, if it takes them awhile to process these?
