1099-R/#945 reporting question

[pmacduff]

I have an Employer with a 401(k) Plan without a separate Trust EIN #. Earlier in the year (calendar year plan) the Employer processed a direct payment distribution with the appropriate withholding under the Company EIN #. The Employer applied for & received and EIN for the Trust around mid-year. Once they received the Trust EIN, they had another distribution requiring withholding. They withheld and deposited using the new Truste EIN number. What will I use on the 1099-R forms? Should I do 2 different forms using the different numbers? What about the #945 form in January? Also 2 filings? I'm thinking that for the IRS to reconcile the deposits made, separate forms will need to be filed for 2003. Any comments/suggestions appreciated! (P.S. I did not know the client had done this, or I would have had them continue to use the Employer EIN for the balance of 2003 and the Trust EIN for 2004 going forward!!!!)

[Ron Snyder]

I have seen situations where using the employer's EIN resulted in problems with reconciling the employer's monthly/quarterly tax deposits. IMHO, the safest option is to send a copy of the original 945 (employer's EIN) and the "amended and corrected" 945 (Trust ID no.) to IRS with an explanation that the EIN was incorrect on the form files and requesting that they properly show the funds as being deposited under the Trust EIN. You may call their taxpayer assistance line for help.

[pmacduff]

Thanks for the info! Do you think, since the plan year isn't over yet, it is worthwhile to have the client call the IRS now and try to get that first deposit relogged under the Trust ID #? In January we would only have to have the client file one #945 with the Trust ID. Plus I can do all the 1099-R forms with Trust ID. I know it's late in the year and maybe there isn't time????