Schedule R

[stephen]

The instructions for the Schedule R seem to indicate that the Schedule R does not need to be filed for plans without Money Purchase provisions and all distributions being made in cash using the employer's EIN. Any comments?

[Tom Poje]

the way we have read the instructions is that line 1 is normally blank since distributions are almost always in cash.

line 2 provides the trust EIN

and then if its a profit sharing plan nothing else.

absoultely great! the only thing we put on the form is the trust EIN, but we still file if there was a distribution.

[Kristina]

Tom's interpretation of the instructions matches the IRS explanation of the form. (I tend to think of the Sch R as the Schedule Ridiculous.)

[Earl]

particularly since MP plans seem destined for the dust bin of history.

[R. Butler]

I agree with Stephen's understanding of when to file. If the plan isn't a DB or MP plan, if there are only cash distributions and if all 1099-R's are filed using the EIN of the plan sponsor then a Schedule R isn't required.

[Guest Hans Moleman]

I never thought about it before, but I too agree with Stephen's assessment.

[Kristina]

Aha. This is a change in instructions from 1999 to 2000. (Wouldn't it be nice if they would type in bold any instruction that is different from the prior year?)

So for 1999, one would enter the EIN of the payor (or the EIN shown on the 1099) even if it is the ER's EIN.

For 2000, one would only enter an EIN on line 2 if it is different than the EIN shown in Item D. If it is a profit sharing plan and item 1 is 0, and the EIN is the ER's, then no Sch R is required.

This now begs the question as to why the ER's EIN is being used to report distributions from a Qualified Plan. With the electronic deposit requirements, does it not make more sense to have a Trust ID# for the reporting of 1099s, 1096 and 945s than to try to accomplish an electronic deposit of federal income tax withheld from the Trust. I would be concerned that plan funds would flow to the ER to accomplish the electronic deposit of funds. Or maybe I am missing something.

[Tom Poje]

ok, now I am confused.

I looked at page 12 of the 5500 instructions I have:

it says exempt if...

plan is not db....

etc

etc

in the case of the plan that is NOT a profit sharing...

but page49 seems to have the exact verbage (with one exception)

do not complete if

plan is not db....

etc

etc

unless the plan IS a profit sharing

or am I just reading it wrong. I hate it when double nots get tossed in there.

[R. Butler]

Pg 12 and 49 still say the same thing, its just that the DOL wanted to display their linguistic skills.

Page 12 if the plan is not a profit sharing....the 4th criteria applies.

Page 49 says unless the plan is profit sharing....the 4th criteria applies.

It says the same thing stated two different ways, the 4th criteria does not apply if the plan is profit sharing..... or the 4th criteria applies unless it is profit sharing....