8955-SSA

[hunter001]

The instructions to the draft Form 8955-SSA specifically states "The 2009 plan year information cannot be combined with the 2010 plan year information and filied on the 2010 Form. You must use a different form for each year."

Before the draft was released we decided we would report any 2009 on 2010 form. I really dont see a problem with this and it will save us on having to mail paper copies of these as it is anticipated that these forms will be filed electronically for 2010, but that is even quite questionable.

Any opinions would be appreciated.

[Tom Poje]

haven't seen the instructions for form 8955-ssa.(even trying a google search)

since it used to be that you had to report people within 1 year following termination it would seem 'logical' that you would somehow report 'year' by 'year' rather than combining years to meet this requirement.

this in reality makes little sense, but since the IRS is asking for comments, it would be better to put in your comments now.

Written comments should be received on or before January 3, 2011 to be assured of consideration.

Addresses:

Direct all written comments to Gerald Shields, Internal Revenue Service, Room 6129, 1111 Constitution Avenue, NW., Washington, DC 20224.

http://govpulse.us/entries/2010/11/01/2010...r-form-8955-ssa

I suppose one comment would be "what if someone was paid out after 2 years. Does that mean you would need to report them for 2009 on one form as having a benefit, and then report them on a 2010 form as having received a distribution?"

[david rigby]

http://www.irs.gov/retirement/article/0,,id=117588,00.html

Form 8955-SSA, Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits (formerly Schedule SSA (Form 5500))

Beginning with returns for the 2009 plan year, the Schedule SSA (Form 5500) has been eliminated as a schedule of the Form 5500 annual return/report and is replaced with Form 8955-SSA. Plan administrators must file this new form with the IRS and not through the EFAST2 filing system.

Plan administrators are not required to file the Form 8955-SSA for the 2009 plan year and subsequent years until the IRS issues guidance establishing a special due date. The special due date is expected to occur in 2011.

After the Form 8955-SSA and related instructions are available for filing, plan administrators should expect to have a reasonable amount of time to complete and file the form by the special due date. The information reported on the new form will be similar to the information previously required for Schedule SSA.

Caution: The special due date for Form 8955-SSA will not affect the time for filing the applicable Form 5500 or Form 5500-SF for the 2009 plan year through EFAST2.