ESOP1 Posted June 15, 2017 Posted June 15, 2017 On the new Form 5300, Line 12 asks if interested parties have been given the required notice and then says "attach statement". As opposed to all the other lines that say attach statement, the instructions for line 12 say nothing about attaching a statement or what it is supposed to say. If they want a copy of the Notice to Interested Parties, is it too much to ask that the instructions say so? Maybe this is a carryover from the old line 12 which asked a different question but had the attach statement requirement which was then explained in the old instructions? How are people handling this line?
CuseFan Posted June 16, 2017 Posted June 16, 2017 yes, that is very odd. the NTIP used to get included but then the IRS said it didn't need to be, but it sounds like they want it again. at first I thought they wanted some statement if the NTIP wasn't provided, but the instructions are a bit murky. maybe if you are the type of plan that doesn't need a NTIP you attach a statement to that effect. however, the instructions also say that applications checked "no" will get returned. so if you answer no and include a statement - like this is an owner-only plan - will it get returned? and as the IRS continues to be resource constrained we can expect more of the same. i had been checking yes and not including the NTIP, but I can't say I've used the Jan 2017 revised form yet. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
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