Guest JHeller Posted August 23, 2010 Posted August 23, 2010 If a plan was established in 2008 and contributions were never made: 1.would the plan need to file 5500s with $0 balances? Assuming testing is not necessary since no contribs were made. 2.would the plan need to go through the normal plan termination process? I can't seem to get a straight answer on this.
12AX7 Posted August 24, 2010 Posted August 24, 2010 We've gone through similar discussions on the board. What is the plan year end for 2008? Assuming that you do not have a late filing for the 2008 plan year, I would file with $0.00 assets, but you may get a letter from the DOL questioning the $0.00 balance the client has reported. I would terminate the plan through a formal process, but in this case, I would probably not submit for a determination letter. I hear what TPAman is saying, but I would not put myself in the position to advise against filing a 5500 etc.
david rigby Posted August 24, 2010 Posted August 24, 2010 Is there a reason to terminate? I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
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