Michelle Mianecki

The Form 5310 instructions indicate the Form must be submitted online starting 4/26/2021. Has anyone gone through this process? If so, did you create a Company Account under the client or the TPA? Seems a company account must be created under the client, but then the client has to complete all the info. and upload the necessary attachments which may be difficult for the client to handle. We have called the IRS and they did not have any guidance.

In answer to your question on the provisional report, I believe you have to subscribe to FIS's added reporting module service to access this.

A company has a group of 80 employees that are part of a large union plan. The contract has not settled and negotiations are not happening at this point. What happens to these 80 employees? Are they now non-union employees and have to be included as not benefiting in the non-union 401(k) plan? Do the employees have to first formally disavow the union in order to be considered non-union?