Limitation Year for 415(c)

[Guest lvegas]

The existing 415© regs indicate that the deadline for treating a contribution to a plan as an annual addition for a limitation year generally is no later than 30 days following the end of the period in Section 404(a)(6) (which if I understand correctly is basically the tax return deadline relating to such limitation year, including any extensions, for the contributing employer). How does this work for a multiemployer plan? In other words, must the plan know what deadline applies to each employer, or does it use its 5500 filing date as the deadline?

[Effen]

Can you be more specific with your question? What is the actual situation you need help with? DB or DC?

Mulitemployer plans are exempt from some of the 415 limits.

[Guest lvegas]

It's a multiemployer MPPP DC plan. 404(a)(6) provides generally permits, for deduction purposes, contributions to have been made on the last day of the preceding year if the payment is on account of such prior year and is made not later than the time for filing a return. The specific question then is whether the plan needs to know (for 415© testing) the tax filing deadlines of each of its contributing employers to determine whether contributions can be credited as annual additions in the immediately prior limitation year (which I think is likely), or whether another approach is required (i.e., the Form 5500 deadline for the plan).