Do all qualified plans need to include Schedule T with their 5500 fili

[Guest Peter Riggins]

Do all qualified plans need to include Schedule T with their 5500 filing for the 1999 plan year or is Schedule T included just for cross-tested plans?

[Cathy from Chicago]

During the ASPA webcourse, the leader said Schedule T replaces the prior 21c attachment. Our position on its completion is that for all plans with the 410b test results of 100% benefitting, we're simply checking that box (not at office and don't remember the box letter). For our New Comparability plans, we complete the ratio info on page 2. I'm not totally convinced this is the right approach but that's the one we've selected.

[Kristina]

first, be aware that Sch T pertains to 410(B) only. While Cross-tested plans must pass 410(B), they must pass 401a4. Sch T has nothing to do with 401a4. Therefore, every plan must file a Sch T, unless you can rely on the substantiation guidelines of Revenue Procedure 93-42 for two out of three years.

If all disaggregated portions of the plan qualify for any items listed in Item 3, then page 2 is not completed.

If you have a profit sharing plan with no contribution for the 1999 year with 401k and 401m features, the IRS has instructed that Items 4c and 4d be completed as though there were a profit sharing contribution and Item 4e for the 401k and 401m portions. Yes, I know it's not explained that way in the instructions, but I got this same answer from three different parties at the IRS.