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Deduction question when plan year different than tax year


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I feel guilty asking a question when I've never answered any.  I've always had to give all of time to getting everything done, and usually much too close to the deadline.
 
The question involves a cash balance plan year end 9/30/2021.  Tax year ending 12/31/2021.  There was no minimum funding required, and no contributions were made by June 15, 2022.  So the Schedule SB will show no contributions for the 9/30/2021 plan year. The company nevertheless wants to make a contribution and be able to deduct it on the 12/31/2021 tax return.
 
The question is, if a contribution is made by the due date of the 9/30/2021 Form 5500 - 7/15/2022 - and we therefore show this as applying to the PYE 9/30/2021, would that make it deductible for the 12/31/2021 tax year? 
 
The issues are: 
 
1):  The general rule is that when the plan and tax years don't match, the deduction limits can be based on the plan year ending in the tax year (plan year 10/1/2020 to 9/30/2021), the plan year beginning in the plan year (10/1/2021 to 9/30/2022), or a combination based on the overlapping months of each.  That method needs to be selected the first year the tax and plan years differ, and keeping the same method each year. 
 
2):  Here, we have followed the method of the deduction for the tax year being based on the plan year ending within the tax year, so for the 12/31/2021 tax year, the deduction is based on the 9/30/2021 plan year.
 
3):   Since the Schedule SB will not show any contributions, would a contribution made by July 15, 2022 actually be applicable to the plan year ending 9/30/2021, or does the fact that it is being made after the minimum funding deadline and will be shown on the 9/30/2022 Schedule SB, make this a contribution for the 10/1/2021 to 9/30/2022 plan year, despite it being reported as for the 9/30/2021 on the 5500 form?  If this must be considered a contribution for the 9/30/2022 plan year, then the deduction would need to be reported on the 12/31/2022 tax year return.
 
(There is a chance the rules are that the timing issues in #1 above, only apply to how the deductible amount is determined for the tax year, and unconnected to what year the contribution is made.  Another words, if a contribution is made by the due date of the 12/31/2021 tax return (9/15/2022), it doesn't matter which plan year it applies to, as long as the amount being deducted is not more than the deduction limit for the plan year ending in that tax year (the 9/30/2021 plan year in this case).
 
Thanks,
Craig Schiller

 

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<<if a contribution is made by the due date of the 9/30/2021 Form 5500 - 7/15/2022 - and we therefore show this as applying to the PYE 9/30/2021,>>

 

I don't think a contribution made in July 2022 can be reported anywhere on the Form 5500 (or Schedule SB) for the plan year ending 9/30/2021.   Contribution must be made by June 15, 2022 to be included in the financial reporting of the Form 5500.

 

....  Jeff

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Deductibility is separate from minimum funding requirement.  Ideally you would like to tie the SB to the tax return for visibility puposes, less explaining to do the IRS if ever examined, but not required.  If your fiscal deductibility period closes before 9/30/2022, then you could still make a contribution against the 9/30/2021 annual limit.  And if you've never made a contribution during this gap period, then you haven't yet established the precedent for how to handle it.

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