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Form 5330 - Funding Deficiency - late from the start


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Just want to make sure that I have this straight. We have a client that ended up not depositing the minimum required contribution by the 8 1/2 month funding deadline, therefore incurring a deficiency. The tax itself is reported using Form 5330. At the time that the 5330 is ordinarily due (7 months after plan year end), we of course did not file for an extension on the 5330 as we had no expectation that we would need to file (funding deadline had not even come when the 5330 is due).

Just want to make sure that i understand the logic: We filed 5330 after the triggering event occurred 8 1/2 months after PYE when the client missed the funding deadline, so off the bat the form is late. So not only owe the 10% excise tax, but also get followup late filing penalties because we didn't extend the form. Or am I missing something?

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