8955-SSA (Combined Filings)

[PainPA]

How does the IRS know if I am filing a Combined 2009 and 2010 filing?

The instructions I am reading doesn't seem to differentiate. What am I missing?

[Tom Poje]

you are missung the Q and As the IRS released

http://www.irs.gov/retirement/article/0,,id=238940,00.html

in particular, #3

Even though the PY 2010 Form 8955-SSA is available to the public, can I still combine PY 2009 and PY 2010 data on the PY 2009 Form 8955-SSA?

Yes, plan administrators can continue to use the PY 2009 form for the combined 2009 and 2010 data even though the 2010 form has been released. As stated in the Instructions to the 2009 Form 8955-SSA, plan administrators may use a PY 2009 form to report information for the 2010 plan year, or combine the information for the 2009 and 2010 plan years on a single PY 2009 form. The release of the 2010 form does not affect this rule.

If you file one Form 8955-SSA covering both 2009 and 2010 reportable employees, the 2010 reportable employees are treated as reported in 2009. Enter the beginning and ending date for the 2009 plan year on the Form 8955-SSA when combining information for the 2009 and 2010 plan years. For example, a plan that reports on a calendar year basis and combines information for the 2009 and 2010 plan years should enter January 1, 2009 as the beginning date and December 31, 2009 as the ending date.

[PainPA]

I guess I have too much holiday booze in my system that is clouding up my thinking...

If I combine the filings on the 2009 which I have done, list the plan year a 1/1/2009-12/31/2009 and not voluntarily file any ADD's for someone that left in 2010. I still do not understand how they would know if I missed the 2010 filing when I decide to file 2011 later. There will be a skip in years for 2010.

I thought by filing the 2009 we would place the year as 1/1/2009-12/31/2010 on the top of the form.

[Tom Poje]

Not filing an 8955-SSA would simply mean you didn't have anyone to report in that year. (hopefully that is a true fact)

That's no different than if you have no distributions and you don't file a Sched R. you don't worry about skipping a year in regards to that attachment do you?

[chc93]

I agree with Tom. If I recall correctly, the initial 8955-SSA instructions said that a form must be filed each year. However, the final instructions say that the form should be filed only for years in which there are reportable participants. So you file a 2009 form and report both 2009 and 2010 participants, and don't file a 2010 form. That is no different that not filing a 2009 form at all if there are no reportable participants for 2009 and 2010, or not filing a 2009 (or 2010) form if there are no reportable participants for 2010. Then if there are reportable participants in a future year, you file a form for that future year. That's also how the previous Schedule SSA was done, or at least how we've done it (and I didn't think anything finally changed in this regard).

[PainPA]

Agreed... Thank you for the replies... makes sense when thinking like the IRS...

However, why would anyone NOT do combo filing for 2009 and 2010...

[chc93]

Agreed... Thank you for the replies... makes sense when thinking like the IRS...

However, why would anyone NOT do combo filing for 2009 and 2010...

We combined 2009 and 2010 for all of our plans, except for one. A large bank wanted to keep the SSA information for 2009 and 2010 separate on separate forms (there were large numbers of participants required to be reported for 2009 and for 2010).