PBGC missed contribution reporting

[pixiebear]

I have a client with a DB plan who has decided to delay their contribution until 1/1/2021. Since there is an unpaid minimum contribution on line 11a, how would I answer line 11b about the reporting of missed contributions to the PBGC? I cannot find anything that provides an answer.

[Calavera]

I would probably answer "No other" and provide explanation.

[david rigby]

At the risk of "being picky", with an extended due date of January 1, 2021, the "mailbox rule" is often used as proof of compliance with a statutory or regulatory due date: having a postmark by the date (there might be exceptions).  There are no January 1 postmarks.  If it were me advising a plan sponsor, I would point out the value of a 12/31/2020 postmark or wire transfer.

[Jeff Hartmann]

This is the explanation that we are providing on Form 5500-SF, line 11b:

[x] No.  Other.     PBGC Notification is not required yet because the Funding Deadline is January 1, 2021.”

 

....  Jeff

[david rigby]

IRS Notice 2020-82, issued 11/16/2020. https://www.irs.gov/pub/irs-drop/n-20-82.pdf.

For IRS purposes, the 1/1/2021 extended due date is now (administratively) January 4, 2021.  The PBGC may (but is not required to) follow.

[Jeff Hartmann]

7 hours ago, david rigby said:

IRS Notice 2020-82, issued 11/16/2020. https://www.irs.gov/pub/irs-drop/n-20-82.pdf.

For IRS purposes, the 1/1/2021 extended due date is now (administratively) January 4, 2021.  The PBGC may (but is not required to) follow.

PBGC did follow with an update (recognizing January 4 contributions) to their recent Technical Update  2020-2.

 

....  Jeff