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Posted

Having a hard time determining when to file the Schedule R. Instructions read that if Lines 1-8 are NA it should not be filed. So regardless if a plan needs to use the ratio percentage test to prove it satisfies coverage a Schedule R should not be filed? Am I interpreting this right.

Posted

From the Form 5500 instructions:

A pension plan is exempt from filing Schedule R if all of the following five conditions are met:

• The plan is not a multiemployer defined benefit plan.

• The plan is not a defined benefit plan or otherwise subject to the minimum funding standards of Code section 412 or ERISA section 302.

• No in-kind distributions reportable on line 1 of Schedule R were distributed during the plan year.

• No benefits were distributed during the plan year which are reportable on Form 1099-R using an EIN other than that of the plan sponsor or plan

administrator.

• In the case of a plan that is not a profit-sharing, ESOP or stock bonus plan, no plan benefits were distributed during the plan year in the form of a single-sum distribution.

...but then again, What Do I Know?

  • 3 months later...
Posted
From the Form 5500 instructions:

A pension plan is exempt from filing Schedule R if all of the following five conditions are met:

• The plan is not a multiemployer defined benefit plan.

• The plan is not a defined benefit plan or otherwise subject to the minimum funding standards of Code section 412 or ERISA section 302.

• No in-kind distributions reportable on line 1 of Schedule R were distributed during the plan year.

• No benefits were distributed during the plan year which are reportable on Form 1099-R using an EIN other than that of the plan sponsor or plan

administrator.

• In the case of a plan that is not a profit-sharing, ESOP or stock bonus plan, no plan benefits were distributed during the plan year in the form of a single-sum distribution.

I agree that this is confusing. In my situation, the plan is a single employer profit sharing plan. Single sum distributions were made during the year, but they were not "in kind". In addition, these distributions were made using the EIN of the plan sponsor/plan administrator. Schedule R would NOT be required, correct?

Thanks much.

Thank you.

pj

Posted
It seems to me that you have satisfied the five conditions.

Thank you. That is what I thought, but appreciate the "second set of eyes". Have a great week.

Thank you.

pj

Posted

Also, if the plan has less than 25 participants at BOY, and if Part II would be blank, you don't have to file one regardless of any distributions. (p. 9 of 2008 Instructions for Form 5500). I love these new small-small plan filing requirements, or lack thereof.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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