Trust Identification Numbers

[puzzledbypensions]

Hi. We have been advised that we should apply for a Trust ID for all of our plans that currently use their EIN as the TIN.

Is there a good reason to be doing this? Is there a requirements that a plan have a separate TIN? We had stopped as we had confusion in the past with TIN's being deactivated after non-use.

Thank you!

[ESOP Guy]

There are proposed new questions for the Form 5500 that are going to ask for the trust's EIN.

[puzzledbypensions]

Thank you ESOP Guy. Is it going to be a requirement to have a separate Trust ID for these questions?

Or for the 8955-SSA?

Thank you!

[ESOP Guy]

It looks like for the 2016 (It was first going to be on the 2015) Form 5500 the question is going to ask you for the trust's EIN. It isn't clear what the sanction would be if you put none.

You were always supposed to have one but as you say after making you get one the IRS would make them inactive if you never filed any kind of form using the EIN.

[Bird]

Mmmm. My OCD made me spend about 20 minutes looking at the new Qs, then at old Schedule Ps to see if we always had separate EINs for those plans on a platform where we had no reason to have one, other than for the sake of putting it on the Schedule P - we did always have separate EINs.

I wouldn't go getting EINs now. They might really mean the payor's EIN (a la Schedule R). I can't imagine they want to be giving out EINs that aren't going to be used.

[ESOP Guy]

I can't help but wonder if the reason the IRS wants the EIN on the Form 5500 is to solve the inactive EIN problem. I don't recall ever having that problem back when the Sch P existed. You were using the EIN at least once a year back then. If it comes back to the 5500 you will be using it once a year and maybe it won't go inactive

I don't see a good reason for most plans to have one either but the IRS doesn't need good reasons.

[Bird]

I can't help but wonder if the reason the IRS wants the EIN on the Form 5500 is to solve the inactive EIN problem. I don't recall ever having that problem back when the Sch P existed. You were using the EIN at least once a year back then. If it comes back to the 5500 you will be using it once a year and maybe it won't go inactive

That's great - "We have a problem - we can't stop ourselves from deleting inactive EINs. We solve the problem by requiring entities to put it on a meaningless piece of paper so it is used." Classic.

[K2retire]

I can't help but wonder if the reason the IRS wants the EIN on the Form 5500 is to solve the inactive EIN problem. I don't recall ever having that problem back when the Sch P existed. You were using the EIN at least once a year back then. If it comes back to the 5500 you will be using it once a year and maybe it won't go inactive

I don't see a good reason for most plans to have one either but the IRS doesn't need good reasons.

I remember having that problem when we were still filing Schedule Ps and being told that a Schedule P didn't count as a filing.

[Tom Poje]

The IRS Q and A had the following 'advice'

https://www.irs.gov/Retirement-Plans/Frequently-Asked-Questions-Regarding-the-IRS-Compliance-Questions-on-the-2015-Form-5500-Series-Returns

6. Am I allowed to use the plan sponsor's EIN in place of getting a trust EIN to answer the question on trust information?

No. You should use the trust EIN to report the information on the Form 5500-series returns. If there is no trust EIN, the EIN used on Form 1099-R and Form 945 may be used for this purpose. We encourage trustees to get a trust EIN from the IRS. If a trust’s EIN has been deactivated, the trustee can fax a request to the EP Entity Control Unit in Ogden, Utah at (801) 620-7116 to reactivate it.

[sive12]

Hi, How to apply a separate EIN for a 401k plan? Can you list the steps? I looked at online application form where the last option - 'View Additional Types' --->> Employer Plan (401K, Money Purchase Plan, etc.); This is where it's asking for existing business name, is this the way the plan EIN will be relate to Business EIN?

Is this same as TIN people talking about for the 401k retirement plan??

[GMK]

The IRS Q and A had the following 'advice'

https://www.irs.gov/Retirement-Plans/Frequently-Asked-Questions-Regarding-the-IRS-Compliance-Questions-on-the-2015-Form-5500-Series-Returns

Tom, the link gives me a 404 error (maybe it doesn't like me).

Is there another link?

[My 2 cents]

Hi, How to apply a separate EIN for a 401k plan? Can you list the steps? I looked at online application form where the last option - 'View Additional Types' --->> Employer Plan (401K, Money Purchase Plan, etc.); This is where it's asking for existing business name, is this the way the plan EIN will be relate to Business EIN?

Is this same as TIN people talking about for the 401k retirement plan??

The EIN is not for the plan - it is for the trust or the plan administrator (if not the employer).

[Flyboyjohn]

If you believe there was a Trust EIN at one time but now can't find it is there a way to ask IRS for it?

[sive12]

Hi, How to apply a separate EIN for a 401k plan? Can you list the steps? I looked at online application form where the last option - 'View Additional Types' --->> Employer Plan (401K, Money Purchase Plan, etc.); This is where it's asking for existing business name, is this the way the plan EIN will be relate to Business EIN?

Is this same as TIN people talking about for the 401k retirement plan??

The EIN is not for the plan - it is for the trust or the plan administrator (if not the employer).

I am a single member s-corp owner/employee and a 401k plan written with a business EIN, I read/understand it's not the way it should be since i will be making the distributions and need to issue 1099-r and it required a separate EIN; I am plan on updating my 401k plan with a separate EIN, I am confused and wondering how to apply for it, I am familiar with EIN online applicaiton, but still confused on what options i should be choosing there, tried calling IRS but no luck speaking to a real person., the only closest options on online form is 'View Additional Types' --->> Employer Plan (401K, Money Purchase Plan, etc.);

'

Any thoughts?

[Mike Preston]

You need to hire an administrator for your plan. That firm will help you out.