8955-ssa deadline for non-calendar years

[Beemer]

What would be the due date for the Form 8955-SSA for a June 30 year end plan? There will be participants reportable for 2009 and 2010. Is the due date for 2009 January 17, 2012 or is it the due date of the 2010 return? I see conflicting information out there.

Thanks for any input.

[pmacduff]

I believe that the 2009 info has the 01/17/2012 due date. The 2010 are then due at the regular time with the 5500 filing deadline. That is how we handled our off calendar years and have not had any problems.

I think the instructions do cover this and indicate that if the normal filing deadline for the 2010 info is after 01/17/2012, then you can use that date but only for 2010 filings.

Therefore you have to do 2 separate filings.

If you are going to file them together then I think you need to use the 01/17/2012 date.

[Beemer]

thanks

[mming]

From the IRS website re 8955 FAQs at http://www.irs.gov/retirement/article/0,,id=238940,00.html

Q & A 1 is:

"I understand that the Form 8955-SSA replaced the Schedule SSA (Form 5500). When is the PY 2009 filing data due?

The Form 8955-SSA is to be used for Plan Year (PY) 2009 filings and thereafter. The due date for filing the 2009 and 2010 Forms 8955-SSA is the later of (1) January 17, 2012 or (2) the due date that generally applies for filing the Form 8955-SSA for the 2010 plan year."

Seems that both the 2009 and 2010 forms for a 6/30 YE would be due 1/31/12, with an extension possible to 4/17/12.

[Beemer]

That was how we originally interpreted the deadline, but it seems that there is a difference of opinion out there. I think we are going to assume the deadline for 2009 is 1/17/12 for all plans, just to be safe.