Form 945 - Multiple Plan

[Stash026]

I have a client that maintains two plans, and had tax withholding due to distributions from each plan.  Should these be reported on one Form 945 (it's the same EIN number), or do we file two separate forms?

Thanks!

[Mike Preston]

The 945 is to report activity of a specific EIN. I can't tell whether what you are doing is right or wrong, but in either event the 945 should be for the single EIN and therefore a single 945.  Unless somebody tells you your single EIN is being used improperly, in which case all bets are off.

[CuseFan]

this goes back to previous discussions in this space on having trust EINs, which would be the proper EINs under which 1099 and 945 reporting should be done and which would, if in place, make your question moot as their would be two separate trust EINs and two separate filings. in this case, if using just the sponsor's EIN you should file one 945 that covers the 1099s from both plans. 

[Doghouse]

I can also promise you that if you file 2 945's with the same EIN, one will end up supplanting the other and you will be in for a lifetime of IRS correspondence.

[Earl]

I have been using one Trust EIN for multiple plans of the same employer for decades without issue.

Just be sure to use the plan name associated with the EIN regardless of where the money was paid from.