Schedule R--are many of you filing it?

[Theresa Lynn]

What is your experience over the past three years with the Schedule R? Are you finding that few defined contribution plans (other than money purchase pension plans and stock bonus plans distributing employer securities) are required to file Schedule R?

Thank you.

[JanetM]

I file for all DB and DC plans that made distributions. The line 2 for EIN of payor must be completed even if some plans can skip line 3 listing number of lumpsums.

[Guest Smitty848]

I do the same as JanetM

[Guest rachd]

Is the Schedule R required if there are only corrective distributions?

[JanetM]

Rather than answer your question directly - how about if I say the R is requried if a 1099 is issued.

[Theresa Lynn]

I had interpreted the Schedule R directions to exempt a profit-sharing or stock bonus plan from completing Schedule R if all distributions were in cash, annuity contracts, plan offset amounts, and/or marketable securities. (Who must file) Could someone explain to me what I am missing (i.e., why this appears to be wrong based on this thread's entries)?

Thank you.

[pmacduff]

Line #3 per the instructions is the only line that PSPs & Stock Bonus Plans are exempt from completing. The form still needs to be done if there were any distributions, even in a PSP. The Schedule, I believe, is supposed to be used by the government to cross reference with the 1099-R / 1096 forms, etc. So if any distributions were done, Sch. R should be completed.

P.S. I just double-checked the 5500 instructions; Schedule R, and I think you might have taken part of the section (2) out of context on "Who must file"... If you reread the entire section, it says that ALL must apply, (including that it be a PSP or Stock bonus plan.) The three bullets items above that must also be applicable.

[Theresa Lynn]

I still am confused....

How do you reconcile the following:

A pension plan is exempt from filing Schedule R if each of the following 4 conditions are met:

1) Not subject to minimum funding requirements.

2) No in-kind distributions reported on line 1

3) No benefits reportable on 1099-R using an EIN OTHER THAN plan sponsor or plan administrator.

4) If not a psp, stock bonus plan, or ESOP, no plan benefits distributed in a lump sum....

So, if a profit sharing plan providing cash distributions reported on a Form 1099-R with the sponsor's or administrator's EIN, why would you be required to file Schedule R?

(See page 12 and Who Must File on page 51 of instructions)

Thank you for your patience with this....

[pmacduff]

I guess because the majority of my clients have 1099-R forms issued from the Investment firms, I am always completing the Schedule R to report the MFS, Nationwide, etc. EIN number. I agree with you, Theresa that under the circumstances you describe, & according to the instructions, you should not have to file a Schedule R, even if there were distributions. I use the Relius Government forms software (formerly Hyperprep) and you always got an error message if you didn't include the Schedule R. Also - I would always figure to include it is "better safe than sorry"...it is, after all, only 1 page ! Patti

[Theresa Lynn]

Thank you! I was beginning to believe that I was thinking "nutty." Thank you for confirming that my alternative interpretation was possible (even if unusual).

Thanks again!