KTB Posted December 18, 2013 Posted December 18, 2013 Is there a minimum on the number of months that a plan has to be, funded I guess you can say, to be considered a short plan year? I have a plan that ended 10/31 and are wanting to change to calendar year. Can I do a 11/1/2013 - 12/31/2013 plan year? If so, can I still do it this late into December? I looked into the regs about short plan years and can't see a minimum number of months.
david rigby Posted December 18, 2013 Posted December 18, 2013 I'm not aware of any minimum. If you are changing PY to coincide with sponsor's FY, my hunch is that the IRS won't care how long is the short PY, since they will (probably) agree that such a change is a good idea. BTW, the change of PY is accomplished by plan amendment, and it MUST be adopted before the end of the short year. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
My 2 cents Posted December 18, 2013 Posted December 18, 2013 I remember once providing services to a plan that had a short plan year that was only one week long! If it matters, you have to give a full year's vesting service if the person works 1,000 hours in the 12-month period that begins on the first day of the short plan year and also a full year's vesting service if the person works 1,000 hours in the plan year beginning after the short plan year. So for the client with the one week plan year, people working full time got two years of vesting service for a 53 week period! Why would the IRS object to that? Always check with your actuary first!
KTB Posted December 19, 2013 Author Posted December 19, 2013 Thanks for the responses! I appreciate it. Interesting on the one week long year!
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