When is schedule T required

[Guest James Osterhaus]

It is my understanding that the schedule T is required to be filed every third year. There is a rumor going around in the office that if a plan started in 1999-or never filed a C/R that a schedule T never has to be filed for them. The question is, what exactly is the rule on when to file the schedule T. I couldn't find any documentation that would prove or disprove the above. The instructions just say you don't have to file one if your using the three year testing cycle and your relying on coverage information from prior year.

[Guest F1fan]

I believe the instructions to Schedule T prove the rumor as false. The instructions provide, in part, that "Employers using the three-year testing cycle rule in Revenue Procedure 93-42 must file Schedule T for the first year in the plan's testing cycle." I am not aware of any exception that would allow a qualified plan to indefinitely avoid filing Schedule T.