jala Posted December 8, 2008 Posted December 8, 2008 We have just taken over a plan and are unable to determine what their Trust ID was? Since the Schedule P is no longer required, we cannot tell from the prior year's Form 5500. The Schedule R reflects the ID number of the prior recordkeeper/broker that took care of distributions, tax withholdings and tax deposits. The client is not sure of the Trust ID. We looked in FreeErisa, but the older returns are archived. Since we cannot confirm, would we creat a problem by applying for a new Trust ID? If there is an old Trust ID out there, would it create a problem if a final was never filed for that Trust ID? I would appreciate any guidance. thank You
J Simmons Posted December 9, 2008 Posted December 9, 2008 We have just taken over a plan and are unable to determine what their Trust ID was?Since the Schedule P is no longer required, we cannot tell from the prior year's Form 5500. The Schedule R reflects the ID number of the prior recordkeeper/broker that took care of distributions, tax withholdings and tax deposits. The client is not sure of the Trust ID. We looked in FreeErisa, but the older returns are archived. Since we cannot confirm, would we creat a problem by applying for a new Trust ID? If there is an old Trust ID out there, would it create a problem if a final was never filed for that Trust ID? I would appreciate any guidance. thank You It is always easier to get it right up front than to undo and fix later. I'd spend what you need to with Judy Diamond Associates/FreeERISA for it to do a look up for the Trust EIN before I would apply for (another) one. John Simmons johnsimmonslaw@gmail.com Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.
buckaroo Posted December 9, 2008 Posted December 9, 2008 jala, Recently ASPPA released an ASAP (08-33) regarding "Problems with "Deactivated" Trust Tax Identification Numbers". A portion of it said: "We were also informed that a taxpayer can verify the status of a Trust EIN by faxing a request to “EP Entity” (fax number 801-620- 6900). On the fax, you should request verification of the Trust EIN and provide the following information: 1. Trust EIN 2. Name of plan 3. Full address of plan 4. Contact name, telephone number, fax number and e-mail address 5. Copy of the original IRS notification assigning the Trust EIN (if available) The taxpayer can further request reactivation of the Trust EIN (if it was deactivated) and IRS EP Entity will reactivate it. (We’d recommend that the taxpayer request confirmation of the reactivation). Note that this status and/or reactivation request must either come directly from the taxpayer or if submitted by a practitioner, it must be accompanied by a properly completed and signed Form 2848." Maybe you could fax all of the info (without the TIN) and see if they could help you or point you in the right direction.
BG5150 Posted December 9, 2008 Posted December 9, 2008 So, I'm guessing the employer does not have copies of the plan's 5500's for past years? QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
JanetM Posted December 9, 2008 Posted December 9, 2008 Plan Sponsor should write to: Public disclosure room N-1513 EBSA DOL 200 Constitution Ave NW Washington DC 20210-1111 Request copies of the 5500s from 2006 and prior years. Not sure why you can't find in FreeErisa, P was filed up to 2006 plan year. That is the latest available. JanetM CPA, MBA
Bird Posted December 9, 2008 Posted December 9, 2008 I dunno, would it really be the end of the world to apply for a new one and then say "oops" if the old one turns up? There's a pretty good chance the old one was deactivated anyway, since it was rarely or never used. Ed Snyder
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