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Posted

A client is filing late 5500s in DFVC program. During the years in question, the plan was in payout status - the corporation was still in existence but there were no employees. So do we list 0 employees on Schedule T? And does that mean that it passes by ratio percentage? (I keep thinking 0 divided by 0 is 0 which is decidedly less than 70%.) Are those answers likely to flag an audit?

There were no contributions made during these years; all participants were fully vested and most had taken lump sum payments already. The plan was for a small physician's practice and it's just the two doctors left who have accounts. We're talking about whether they'd like to terminate the plan and roll their balances into IRAs. But before we can get to any of that, we've got to take care of these matters!

Posted

Figured out the answer to my own question (amazing how stepping away from your work can give you a fresh start).

For the plan years in question, no employee received an allocation or accrued a benefit under the plan. Hence, we check box 3b and do not complete the rest of this schedule.

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