Schedule R lines 4 & 6

[Guest Alison Williams]

I need some help please. I have a defined contribution plan that is a money purchase plan. They have made their minimum required contribution for the plan year and have so indicated on lines 6a and 6b. They did not make any elections or amendments as described in line 4 and therefore checked the "N/A" box. However, my software is giving me an edit check that lines 6a and 6b should be left blank when line 4 is marked "N/A". Any guidance will be appreciated.

[Guest MEGary]

Alison-

Typically, I would check N/A for a profit sharing or 401(k) plan that are not subject to the minimum funding standards. If you didn't make an election under Code Section 412©(8) or ERISA section 302©(8) and the plan is subject to minimum funding, I would check the NO box. You shouldn't have any edit checks at that point.

[billfgrady]

Does Schedule R apply to a profit sharing plan? What if the plan is top heavy for the year?

[david rigby]

According to footnote 5 on page 12 of the Form 5500 instructions:

A pension plan is exempt from filing Schedule R if each of the following four conditions is met:

- The plan is not a defined benefit plan or otherwise subject to the minimum funding standards of Code section 412 or ERISA section 302.

- No in-kind distributions reportable on line 1 of Schedule R were distributed during the plan year.

- No benefits were distributed during the plan year which are reportable on Form 1099-R using an EIN other than that of the plan sponsor or plan administrator.

- In the case of a plan that is not a profit-sharing, ESOP or stock bonus plan, no plan benefits were distributed during the plan year in the form of a single sum distribution.

[billfgrady]

I'm sorry: I should have been more specific. I've thoroughly read the instructions to Schedule R, Section 412 of the Code and ERISA Section 302. However, although I know that Section 412(h) of the Code exempts profit sharing plans from the minimum funding requirements under Section 412 of the Code, I haven't been able to determine whether a profit sharing plan is subject to the ERISA Section 302 requirement. Does the definition of "employee pension benefit plan" under ERISA Section 3(3) sweep in profit sharing plans? I would think not.

[Blinky the 3-eyed Fish]

- In the case of a plan that is not a profit-sharing, ESOP or stock bonus plan, no plan benefits were distributed during the plan year in the form of a single sum distribution.

This portion of Pax's response should answer your question.