Filing Form 5330 with Different Fiscal Year than Calendar Year

[Guest nickyj8]

I have a client who had a late salary deferral deposit in September 2003 that was corrected in February 2004. The plan year is the calendar year but the employer's fiscal year is July 1 to June 30. Because the late deposit spanned 2 plan years (2003 and 2004) but only 1 fiscal year (7/1/03-6/30/04), I am a little confused on how to complete the Form 5330.

I was thinking of filing one 5330 with the transaction listed twice in Section VII, once with the date of the late transaction and the tax on the amount involved in 2003 ($209 in lost earnings) and a second time with a date of 1/1/04 with the amount involved in 2004 ($92 in lost earnings). Does that sound reasonable?

Any advice on this would be appreciated. I can't seem to find very much guidance in situations where the fiscal year is different from the plan year.