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Posted

Plan effective 1/1/14, only principals and wives, so no 5500 filing.

1/1/15, employee eligible and have to file 5500-SF. Box checked for first filing.

Q- Because plan effective the prior year and there is a participant count at 1/1/15, the IRS will probably send out a Notice, why are participants and money in the plan as of the beginning of the plan year?

And then do the merry-go-round explanations to/from IRS?

Suggestions, rather than submit and see what happens?

Posted

No suggestion. Just submit and see what happens. This actually happens all the time. Sometimes, they may send a letter, which requires an extra step of providing them an explanation. It's just one of those unfortunately imperfect situations we deal with.

"Merry-go-round" may be a bit of an overstatement. Then again, it may be a bit of an understatement :-)

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

Posted

Shouldn't be an issue.

But if you do get noticed, let the merry-go-round begin. Should be a simple matter of 1 letter stating plan was not required to file in 2014 and why it wasn't.

Posted

I agree, should't be an issue. I have had the same situation on quite a few plans and it has never been questioned. On the other hand, if you end up with only owner+spouse again and go back to EZ, they might ask where your 5500 is if you decide to not file because you are under $250,000. It is still a one letter explanation though...

 

 

Posted

S corp

Are you sure they're not subject to ERISA? When making this determination, a plan covering only partners of a partnership is different from a plan covering owners of a corporation.

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

Posted

If it is an S-corp then a 5500-SF was required for 2014. Hie thee to DFVCP.

Posted

S corp

Are you sure they're not subject to ERISA? When making this determination, a plan covering only partners of a partnership is different from a plan covering owners of a corporation.

Good Luck!

Where does it say that? I've heard it mentioned, just never seen it in print/

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

When you look at the instructions on "Who may file a Form 5500EZ", there is a clear differentiation for "Partners in a Partnership". So, if you and I are both 50/50 owners of an S-Corp (and are the only employees), then we do not get the option to file a Form 5500EZ.

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

Posted

There was some discussion on this topic just a few weeks ago.

http://benefitslink.com/boards/index.php/topic/59219-one-participant-plan-or-not/

And, of course, I remember the conversation. I never learned to add a link to another conversation into a current discussion. As a result, I often find myself merely speaking to what's right there in front of me at that single point in time :-) It's a bad habit, I know. It has to drive the bandwidth through the roof :wacko:

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

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