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Form 6088 for Collectively Bargained Plans

Kent Allard

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The accompanying instructions to the Form 6088 seem to indicate collectively bargained defined benefit plans must file a Form 6088 along with a Form 5310 submission. While clearly collectively bargained defined contribution plans seem less expected to file a Form 6088, collectively bargained defined benefit plans seem to lack only the expectation to input information into g. Revenue Procedure 2021-4 seems to present confusion, as at a particular section, this guidance seems to waive the expectation to file a Form 6088 for all collectively bargained plans. 

Please provide further salient, affecting guidance.

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Agree that there does appear to be inconsistency between the 6088 instructions and the Rev Proc, but that section of the RP then goes on to reference filing per the 6088 instructions, which do call for the 6088 for a collectively bargained DBP. The primary (sole?) purpose of the form is for IRS to monitor accrued benefits versus 415 limits, to which cb'd plans are subject, so it makes sense that a 6088 would be required. 

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services


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