5500-EZ for Affiliated Service Group member - Minimum to file

[TPApril]

Multiple Doctors in affiliated service group arrangement, each with their own plan, filing 5500-EZ's. Doctors are tested with staff plan

New doctor starts up her own plan. Is there a reason she needs to file 5500-EZ as long as her balance is under $250,000?

[TPApril]

Thought I'd repost my question as my timing may have been off right before the holiday weekend. Or perhaps it's obvious? Sometimes you just never know.

[Lou S.]

Based on the 2015 instructions (I haven't read the 2016 instructions), it would appear you need to file.

See page 2 of the instructions https://www.irs.gov/pub/irs-pdf/i5500ez.pdf

I base this on the example in the instruction and this being an ASG but someone may have a different reading then I do.

 

Quote

 

Example.

If a plan meets all the requirements for filing

Form 5500-EZ and its total assets (either alone or in

combination with one or more one-participant plans

maintained by the employer) exceed $250,000 at the end

of the 2015 plan year, Form 5500-EZ must be filed for

each of the employer's one-participant plans including

those with less than $250,000 in assets for the 2015 plan

year.

 

 

I guess it comes do to do you view the Dr as standalone "employer" or the whole ASG as the "employer".

Since for testing they are one big happy family under the ASG, I would take the conservative approach and file.

 

 

 

 

 

 

[TPApril]

What is an example of one-person plans maintained by the same employer? I've just never had accounts such as that.

[Mike Preston]

Consider a partnership with 4 equal partners and no employees.  It is not unusual to set up 4 separate plans, one for each of the partners.  The partnership maintains 4 one-person plans. If it maintained 2 plans, each with 2 partners, then the partnership maintains 2 one-person plans (which I understand stretches the literal definition one would expect).

[Lou S.]

20 hours ago, TPApril said:

What is an example of one-person plans maintained by the same employer? I've just never had accounts such as that.

It used to be more common when the PS limit was 15% of pay to have a PS plan and a 10% of pay MP plan.

Now I suppose someone could have a DB plan and 401(k) plan. The DB Plan could very rapidly go over the $250K limit while the 401(k) might take a long time to hit the $250 limit.

[TPApril]

Okay, I think I get it, which means i incorrectly described my original question.

Case at hand is not ASG but rather LLC where each Partner sponsors their own plan. This would effectively be treated as the LLC sponsoring multiple one-person plans. So in this case, all individual plans must file if the sum of the whole exceed $250K.