Extending Initial Plan Year to Avoid Short Plan Year

[401 Chaos]

Plan sponsor has determined it prefers to have fiscal plan year end rather than calendar plan year end. Is it possible to extend an initial plan year for a newly adopted plan (provided the plan year does not go beyond 12 months)?

Situation involves plan adopted mid-2009 with a calendar plan year end. Can plan sponsor now amend the Plan to extend the Plan Year out to 12 months after the effective date so that it has fiscal plan year end and the first Plan Year is a full 12-month plan year rather than the short plan year ending 12/31 as originally drafted?

What if the match component (or other components) have some last day of plan year requirement? If plan sponsor is willing to give match credit for anybody there on 12/31 that subsequently leaves before the end of the extended plan year, could that work?

[Guest jhall]

Wonder if you could file a Form 5308 to seek approval / confirmation of the extension?

I see the title and general instructions for the Form 5308 address a "change" in Plan / Trust Year suggesting a plan might either extend or cut short a Plan Year using the form.

Item 6 of Form 5308 and other discussions of the Form 5308 process, however, seem to contemplate that there will be a short period or plan year as a result of the change so it is not clear from that you could extend the short plan year, at least using Form 5308. I do not believe I've ever seen an extension of a previously established short plan year.

[401 Chaos]

Thanks. I like the idea of filing a Form 5308 even though I think we might arguably qualify for an automatic approval (assuming the rules permit an extension rather than merely a shortening of the plan year). Seems we might just leave item 6 blank or otherwise explain that this involves an extension rather than creation of a short plan year.