New DB Plan - identifying 1st 5500 filing year

[TPApril]

One-person DB plan, adopted in 2022 for 2021.

First contribution deposited in 2022.

Say contribution is > $250,000, file 5500 for 2021?

Say it is less, no 2021 filing needed.

Let's move to 2022:

2022 contribution deposited in 2023, taking net balance over $250,000.  File for 2022, or ultimately file first 5500 for 2023?

[Lou S.]

You'll always need a Schedule SB for the contribution year, signed and delivered to the Plan Sponsor.

If it's an EZ the SB isn't filed with IRS but is maintained and subject to audit.

If it's adopted in 2022 for 2021 under the SECURE Act your first required filing is 2022 Plan year (assuming you are over $250K) in which case you attach the 2021 and 2022 SB to the 2022 filing but if it's an EZ you don't attach the SBs.

In your last example, it would depend if you are filing on a cash basis or accrual basis whether or not you are over $250,000 for the 2022 plan year for purposes of required EZ.