Kristina

A final filing needs to be filed for the DB plan to avoid letters from the IRS The 2014 and 2015 filings need to be done for the 401k plan using 002 as the plan number. Then the 2016, 2017 and 2018 forms need to be amended using the correct plan number and with Item 4 completed to show what was used before.

For 5500 Series purposes, always use the year of the plan year beginning date.

Even though no commissions were paid, there were probably premiums paid that should be reported on page 4

EFAST will accept either prefix. So any filings you submit before you have submitted your Application for Renewal of Enrollment and paid the fee would use the 17 prefix and after the 20 prefix. If you are recently enrolled and have to meet additional requirements before your renewal is approved, use the 17 prefix until you are notified of your renewal.

There will have to be amendments since SECURE only changes the RMD beginning age for those who turn 70 1/2 after 1/1/20. Yes, people there will be two groups of people subject to RMDs: those who started at 70 1/2 and those who start at 72

The TCC to access the 1099R section of FIRE has ALWAYS been different than the TCC used to file Form 8955-SSA thru the FIRE system. If you selected more than one filing type on the same 4419, it just means that the IRS would assign a different TCC for each filing type.

Comes up fine for me. Try a different browser.

The IRS posted a draft Form 8822-B as of November 18, 2019. It does not reflect any of the SECURE Act provisions, so expect another draft before the form is finalized, or soon after it is finalized. (Changing the course of a proposed form can by like changing directions on the Titanic) The current instructions do not mention the penalty for not filing, but it has been a main point of annoyance for the IRS that plans are not filing an updated 8822-B when the responsible party or the address change. The data on the Form 8822-B forms part of the IRS master record for the plan. The Responsible Party is the one assessed with late filing penalties for late 1099Rs. The fact that you did not receive the late filing notice because it went to the attorney who helped establish the plan and has since retired and moved away means nothing to the IRS. The responsibility stays with the plan.

Remind the son that if the check is written to him it will be taxable to him for year in which the check is written. He should just accept it. I'm assuming you have determined that the son is, in fact, the beneficiary.

EFAST maintains only 4 form years at a time, currently 2015, 2016, 2017 and 2018. On 1/1/20 it will be 2016, 2017, 2018 and 2019. If you are filing a delinquent or amended filing for a year prior to 2015, you will need to file on the 2018 5500 Series, but may be required to include correct year schedules. Make sure that 2014 filing on the 2018 forms is completed by 12/31/19, as EFAST will reject it out of hand on 1/1/20 when they are looking for the 2019 forms.

A bigger problem is the Form 5330.

"So you are not providing the facts necessary for us to understand what happened. More details are necessary including the exact name of the Plan." I agree that the necessary details are missing. HOWEVER, the exact name of the plan is not one of them and should not be published under these circumstances on a Discussion forum.

Just a thought; if you file the 5500 series as final and that shows total assets and a liability so that net assets are zero, an edit test will be flagged telling you that the filing has not met the criteria for a final filing.

While the instructions say that a D code is used for previously reported participants, a D code for one not reported or for whom a A code can not be verified, precludes questions years down the road. Oh, and IRS/SSA do not seem to tie A codes and D codes together.

I agree with ESOP Guy, except that one does not have to report the terminee who is paid out before the filing of the 8955-SSA as a A code, BUT one should report the terminee as a D code either for the 2018 year, or the 2019 year.

You need to narrow this down some. There are thousands of email addresses and the Address depends. You might go on the IRS.gov website and look for the addresses. Or contact your local IRS office.

As I heard from EBSA, the model language was just that. A Model. There is no requirement to include the PRA language. I believe the PRA language was included in the OMB submission and whoever released the modified SAR after approval just left the language on it. There is nothing like the PRA language to dissuade participants from reading plan disclosures. It doesn't apply to them or their plan and means nothing to them.

An MTIA is a DFE filing and is normally due 9 !/2 months after the end of the DFE year that ended in 2018. Check the instructions for When to File. The instructions for Penalties reference plan sponsors and plan administrators and nothing about DFEs. If you are filing for a calendar year DFE, you have until 9/15 to file the DFE filing.

I believe the incomplete information referenced has to do with the payment frequency and amounts. Not the name. And someone should have looked at the social security card when the participant was employed and should be able to provide accurate information as to the SSN and Name. Otherwise you are dealing with garbage in and garbage out.

I think you are talking about the Voluntary Fiduciary Correction Program (VFCP) and you can file with the DOL using the EBSA Application and Checklist. A lot more documentation is required than what is required for the 5330 filing. DOL does say that the penalty can be avoided under certain circumstances, but there no guarantees. I would advise you to go to www.dol.gov/EBSA and search for VFCP

You can file on the 2018 for for a 2019 year if you are filing before the 2019 5500-EZ is available. There is no need to cross out the form year in the upper right corner. Just make sure you show the correct plan year beginning and ending dates on the form. The rule mentioned about January 1, 2020 applies to EFAST2 filed forms only. If the 2019 5500-EZ is not available until after 12/31/19, you would still be able to use the 2018 form for a short or final year.

The change does not apply to the full SAR for a large Plan. Only to a small plan waiving the audit requirement.

You can only use it when you file the 5500-EZ. I do not believe you can use it when you get a letter about late/not filing from the IRS. I think you confused them.

You might consider using a Reasonable Cause statement for the plan which should have been filed as a Title I plan. For plans where the owner is the only remaining participant for a plan year, the IRS has indicated that the plan continue to be filed as a Title I plan. Their theory is that if there was non-owner employee, it is likely that there will be another non-owner employee and the plan should not shift in and out of Title I.

I believe that prior year filings are not published on the website.