Guest mcfeldman Posted July 3, 2007 Posted July 3, 2007 when the EA for a plan changes within the same actuarial firm, does that change have to be reported on Schedule C to Form 5500? A number of years ago this question was answered "yes", in particular Gray Book 1992, Q-36. Has anything changed?
david rigby Posted July 3, 2007 Posted July 3, 2007 I've seen nothing since, GrayBook or otherwise. There are several discussion threads on this topic on this Message Board, but they will likely point you to the same result. Although it sometimes (not always) seems silly, I see no reason not to follow the advice in Q&A 92-36. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
Peter Gulia Posted July 3, 2007 Posted July 3, 2007 The instructions for Schedule C seem to say that an administrator completing Part II should consider as the service provider not the natural person but rather the corporation, partnership, or other business organization through which an accountant or actuary practices. See page 33. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
WDIK Posted July 5, 2007 Posted July 5, 2007 The instructions for Schedule C seem to say that an administrator completing Part II should consider as the service provider not the natural person but rather the corporation, partnership, or other business organization through which an accountant or actuary practices. See page 33. I was corrected on that line of thinking several years ago. http://benefitslink.com/boards/index.php?showtopic=24725 ...but then again, What Do I Know?
Guest Dell Posted July 6, 2007 Posted July 6, 2007 It really does seem silly. The common sense version is you generally engage the actuarial firm, not an individual within the firm. Also the Sch. C is obviously geared to reporting a "termination" of the actuary, which doesn't make sense when the individual EA is just rotated by the actuarial firm. Does it make sense that we have to send a letter to the EA informing him that he was terminated because his own firm simply assigned another EA that particular year; and then again the next year if he takes over the engagement again? But, that is only common sense, and I guess there is no point in relying on that. It does seem clear they want it reported; but it is just busywork.
david rigby Posted July 6, 2007 Posted July 6, 2007 Of course that is the silly example. But sometimes, XYZ Actuarial Co. assigns Actuary B because Actuary A is no longer employed with XYZ. And the IRS does not draw a bright line between these situations. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
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