Under $100,000 Exemption...

[Guest RONNIE WASEL]

Employer is single participant, no employees, and sponsors coupled MP and PS plans. In the past the total combined plan assets have not reached $100,000, and thus no 5500-EZ was ever filed.

Question - For the plan year ended 12/31/01, the value of the assets combined was $83,000. The contribution that was made on 9/13/02 for the 2001 plan year was $35,000.

Does that mean that the plan has assets of $118,000 for purposes of this threshold?

Bottom line - do they need to file a 5500-EZ for 12/31/2001?

Thanks,

Ronnie

[Cathy from Chicago]

We file EZ if combined assets >100,000

[Blinky the 3-eyed Fish]

If you are preparing the 5500 on an accrual basis, you would need to file. If it's on a cash basis, you do not.

[Lynn Campbell]

What are the filing requirements if the client has an inactive Keogh plus new corporate plans? The corporate plans total less than $100,000 in assets (husband and wife only participants) but with the Keogh added in, the total is greater than $100,000... Would this mean client should file 5500-EZ for all Plans, using old ER ID# for the Keoghs? Thanks for all input.

[Cathy from Chicago]

Lynn, in my opinion, yes, an EZ should be filed for each plan. I would think he would want to get his Keogh EIN changed to match his new EIN. What I don't know is if you can simply change the EZ to the 'new' number or if some formal change has to be made with the IRS.

[jaemmons]

According to the 5500-EZ instructions you will need to file a final for the MPP. Under "Who May Not Have To File" there is a note which indicates that "all one-participant plans must (bold-type) file a Form 5500-EZ for their final (bold-type) plan year even if the total plan assets have always been less than $100,000..."

That's pretty direct statement, so I would file a final EZ for the year of merger.