extensions for form 8955-SSA

[Tom Poje]

hurray. according to ASPPA looks like we might not need a signature on these extensions!

On June 11, 2012, several members of GAC met with individuals from the Treasury Department and the IRS. At the meeting, ASPPA was notified that regulations will be issued that will allow the Form 5558 to be filed to extend the due date for filing Form 8955‐SSA without a signature. ASPPA was also informed that regulations are expected to be issued before the end of July 2012.

[chc93]

Couple of concerns I have... What is "end of July 2012"? Is it July 20? July 31? Would I mail the 5558 without signature, before the regs are issued, and *hope* they are issued by July 31? Will there be retroactive relief if the regs are issued after July 31? I guess I don't know what I'm doing yet...

[Guest BCJames]

We will probalby wait and mail them all on July 31, with signature, if there aren't any regs yet.

[mwyatt]

A practical note here with the whole concept of a separate filing of extension for 8955-SSA. What if the reason for filing an extension of time for your client's 5500 is due to the (not so rare) fact that they haven't yet provided you with any data to perform the valuation? Without the data, you don't even know whether or not you even have a need to file the 8955-SSA in the first place. Do you preemptively file for an extension regardless for the 8955-SSA as well, and if it turns out that the 8955-SSA wasn't needed you're covered (or have you started a trip down the rabbit hole with the IRS because they never received the 8955-SSA that you requested an extension for?).

[Mike Preston]

Isn't there a one year delay? Barring re-hires you therefore know, don't you?

[mwyatt]

Unless those one-year delays were paid out in 2011 and then you don't need to report them (and you don't know because client hasn't gotten you the data yet to see if paid out).

[Mike Preston]

Maybe this argues for a regimen of always reporting (even when not required - but it would be based on the information available at the time) and then reporting the payout in the following year. More work, for sure.

[DMcGovern]

I see the iRS issued REG-153627, proposed regulations to add the Form 8955-SSA to the list of forms that provide for automatic extensions. Looks like we can rely on this proposed regulation - WHEW!

[mwyatt]

Given past experiences with Ogden, anyone want to place any bets on how many letters clients will receive rejecting the extension because it wasn't signed?