Schedule I - A really quick question

[Lori Friedman]

A new plan has 620 participants at the end of its initial year.

Can the plan file a Schedule I, instead of a Schedule H? We determine a "small plan" by the number of participants at the beginning of the year. For a new plan, of course, the opening count is 0.

Can I use Schedule I, or would that be cheating?

[Lori Friedman]

A very helpful person at IRS telephone assistance just answered my question.

He said that a plan never begins operating with 0 participants. Plan operations commence when it has participants. If a new plan's initial group of participants happens to be fewer than 100, file a Schedule I. Otherwise, file a Schedule H.

[Guest CharlieT]

A very helpful person at IRS telephone assistance just answered my question.

He said that a plan never begins operating with 0 participants. Plan operations commence when it has participants. If a new plan's initial group of participants happens to be fewer than 100, file a Schedule I. Otherwise, file a Schedule H.

Wow, I'm surprised IRS telephone assistance got it right (I'm ex-IRS so I can say that). To amplify, DOL does not consider a plan to be in existance unless it has participants. Therefore, it becomes a plan design issue as to the count of participants on the first day of teh plan year.