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We have recently taken over a pooled profit sharing plan that has several PT loans - 2 loans to disqualified persons and 1 loan in excess of $50k / 50%. The loans have been corrected recently, and I am now preparing the Forms 5330 for the excise taxes. These PTs were never reported on a Form 5500 nor a Form 5330 previously.

In the EOB, Sal states that if the transaction is reported on the annual return, a 3-year statute commences for purposes of collection of the excise tax. If the transaction is not reported, a 6-year statute commences. (Chapter 14, Sec V, Part B, 5; he also references GCM 39475). One of these PTs goes back to 2001 - am I understanding correctly that I only need to prepare 5330s for 2009 - 2014 and that the PTs from 2001-2008 do not need 5330s?

Thanks!

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