Renafesq

In reviewing a draft 990 for a retiree welfare plan, I learned that the prior year 990 was filed on cash basis. For 2015, we received a copy of the Financial Statement for the 5500 audit along with a cash reconciliation worksheet. On the cash reconciliation schedule, there was an account named “benefits payment redeposits” in the amount of over $4mil. I’m not sure if it should be entered on the 990 as revenue under cash method? Or it is related to any benefits accrued in prior years? Upon initial research, I learned that other organizations have listed the benefits payment redeposits as part of the plan's opening balance on the portfolio statements attached to the 990s, but I'm not sure if this amount actually entered on the Form 990 itself. The instructions to the Form 990 did not shed any light. Any help or direction is greatly appreciated!

It appears that there is both so I agree with that...but now the tpa is saying that in this case since this is a non- profit and the profit sharing is completely discretionary, it can also be paid by 12/31. Not sure where she's getting this and since this is a new area for me, I'm not totally sure why it matters that the profit sharing is completely discretionary.

I apologize for that. The client wasn't very clear at first. But I believe the question is regarding both: I need to know what the deadline is for a nonprofit to pay in 2015 safe harbor and profit sharing contributions to a plan? Is it the ultimate filing deadline (10/1716) or the end of the next calendar year (12/31/16).

One add'l follow-up. The client's TPA disagrees and says this: The only Employer contribution that is relevant in terms of a deadline is the safe harbor contribution that is stated in the plan. The safe harbor contribution is a Non-Elective Safe Harbor and the timing of when a safe harbor contribution has to be made can be found in income tax regulation 1.401(k)-2(a)(4)(i)(A). Our reading of this section is that safe harbor contribution made prior to 12/31/2016, can be applied to 2015. Doesn't that reg the TPA referenced related to the ADP test?

Thank you all!

Thank you! I was asking for purposes of Form 5500 filing. The client was advised they had until the end of the PY (which is the calendar year), to make contributions and still include those contribution on the form 5500 filing. Thanks for the info...I'm still a newbie!

What's the deadline for making a profit sharing plan contribution for a calendar year plan for a nonprofit org? Is it the same as for profits?