Elimination of Non-Reporting of Those Pd Prior to 8955 being Filed

[BeanCounterBlues]

In the past, I understood that if a participant who otherwise would have been reportable as an A on the year's 8955 (Sch SSA in the past) - but was distributed prior to the filing of the 5500 and Sch SSA - did not actually have to be reported. I learned at a seminar this week that supposedly the cut off is now the prior year end. So if I'm analyzing the 2010 calendar plan year, and I have a Code A - but that person was fully distributed April 23, 2011 - in the past I would not have reported that person if the SSA was filed after April 23, 2011. The way I interpreted the comments from the seminar was that is no longer permissible - in my example, the person would be reported for 2010, as a code A, and then on the 2011 reporting, as a Code D. This seems like unnecessary work for IRS, SSA, and the plan sponsor and practitioner. My concern is doing it right though (not the amount of work it requires). I'm curious if anyone else has heard what I heard (about the 12/31/ cut off) and / or what approach other practitioners plan to take regarding this issue. Thank you.

[rcline46]

Your answer is in the instructions for the 8955-SSA - page 3 - When not to report a participant.

"A participant is not required to be reported on Form 8055-SSA if, before the date the Form 8955-SSA is required to be filed (including any extension of time for filing), the participant:

1. Is paid some or all of the deferred vested retirement benefit.."

I think this is rather clear.

[BeanCounterBlues]

I thought it was pretty clear too, however is contradictory to what I heard from a noted expert at a seminar. Wondering if anyone out there heard the same thing I did. This same commentator stated that there is conflicting information between Form instructions and published IRS Q&A's on certain issues. Thanks for your comments.

[rcline46]

That is when you raise your hand and ask the 'noted expert' to explain the discrepancy between black and white and his/her interpretation.

Of course, when there are conflicting answers, I thake the one that works best for me!