5500EZ - filing required or not?

[JBones]

I know this is a 5500 question and I asked it on that board, but need an answer quickly and haven't gotten it there.

Assuming all the other requirements are met, when determining whether or not a plan has to file a Form 5500EZ due to having assets under $250,000, is that number based on the actual assets at 12/31/2010 or does it include accrued contributions for the year.

Example, plan has $225,000 in assets at 12/31/2010 and contributes $30,000 during 2011 for the 2010 plan year. EOY cash basis assets = $225,000, EOY accrual basis assets = $255,000. Is this plan required to file?

[Andy the Actuary]

Suppose you were preparing the 5500-EZ. Would you include the accrued contribution as part of the year-end assets?

[ScottR]

I would include the C/R in the asset value.

... Scott

[Andy the Actuary]

I would include the C/R in the asset value.

... Scott

So, Mr. Jbones, if you agree with ScottR, then wouldn't you include this contribution when conducting your $250,000 condition assessment of whether or not a form should be filed?

[JBones]

I would include the C/R in the asset value.

... Scott

So, Mr. Jbones, if you agree with ScottR, then wouldn't you include this contribution when conducting your $250,000 condition assessment of whether or not a form should be filed?

I suppose that if you agree that it must be included, then the assets exceed $250,000 and you're forced to file, if you don't agree, then the assets are below $250,000 and next year would be the first filing.