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Posted

Hi,

We have a money purchase plan that amended their document and changed to a 401k mid year. Question is do I have to complete two 5500, one for the Money Purchase to the date of change, then one for the 401k. The plan sponsor did not change, the plan name did change but I don't think that is of any importance.....

Thanks,

Posted

Thanks! Follow up, is there anywhere on the form to indicate the change from MP to a PS or does it really matter (I still would complete the schedule R where I would put the MP contributions for the half year).

I am in a discussion with a co-worker who thinks there should be two filings.... one showing the final for the MP and a new one for the PS. I have done this in cases when there were actually a PS Plan in place already and the MP being rolled into the PS.

Thanks again.

Posted

You definitely do not have 2 filings. You do have a funding standard up to the date amended. Beyond that I do not recall any place to note the conversion. On another note, was a 204(h) Notice done?

Having braved the blizzard, I take a moment to contemplate the meaning of life. Should I really be riding in such cold? Why are my goggles covered with a thin layer of ice? Will this effect coverage testing?

QPA, QKA

Posted

Yes a 204h was issued for this change. Thanks for the assistance, is there anywhere that shows that only one filing is required in this case? I am in agreement with you that only one is need since the plan was merely amended...

Thanks in advance.

Guest Mauiorbust
Posted

I agree with K2 because at no time did you have two separate plans therefore, only one filing noting a name change if applicable.

Posted

The IRS/DOL identify a plan by the combination of sponsor ID number and plan number. The person who disagrees can ponder how to file two returns for the same plan.

Ed Snyder

Posted

You would also indicate the change with the Characteristic codes in line 8a.

Money Purchase plan would have been reported as 2C, a 401(k) profit sharing plan would use 2E, 2J, possibly 2A and others.

I'm not sure if for 2009 you would report both - I would have to look into that

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