Large Plan & Final 5500 Short Plan Year

[Guest MS TPA]

It appears one of our terminated large plans will not have evryone paid out until after the first of the year. Beacuse the participant count is over 100, an audit will be required for this short year final 5500-correct?

[Bill Presson]

It appears one of our terminated large plans will not have evryone paid out until after the first of the year. Beacuse the participant count is over 100, an audit will be required for this short year final 5500-correct?

Assuming the final year is a short plan year of less than 7 months, the plan sponsor is allowed to make an election to defer the accountant's opinion on the 2010 return and just do a single audit for the entire period.

From the 2009 5500 Instructions:

(2) Short Plan Year Rule: If the plan had a short plan year of seven (7) months or less for either the prior plan year or the plan year being reported on the 2009 Form 5500, an election can be made to defer filing the accountant’s report in accordance with 29 CFR 2520.104-50. If such an election was made for the prior plan year, the 2009 Form 5500 must be completed following the requirements for a large plan, including the attachment of the Schedule H and the accountant’s reports, regardless of the number of participants entered in Part II, line 5.

[Guest MS TPA]

Thanks Bill!!