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I saw the recent ASPPA article about the optional questions on the Form 5500, it also had a few paragraphs about the recent flurry of Form 945 notices that the IRS has sent out. Sorry I don't have the link handy. I actually had a conference call with a client and an IRS person this morning who claimed that for years where there is Zero withholding, the Form 945 was still required. In lieu of filing showing a Zero, the IRS would accept a statement saying no filing was being submitted because there was zero withholding. We have been inundated with client questions regarding these stupid notices. In every instance it is related to a year where there was no filing because there was no withholding (usually a very small plan that didn't even had a distribution that year). the 2015 Form 945 Instructions: https://www.irs.gov/pub/irs-pdf/i945.pdf Page 2, "Who Must File" "You don't have to file Form 945 for thoses years in which you don't have a nonpayroll tax liability" There is no reference to notifying the plans in lieu of non-filing. Is there something I'm missing or is the IRS just being stupid? The IRS person insisted that either a filing showing Zero, or a statement was required. For what its worth, this particular call was regarding as 2013 form, but we have had clients received the notices for multiple/variety of years. I don't recall the rules changing.