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Would a 5500-EZ be required for a plan under $250,000 in this situation? Two separate companies with single participant plans controlled the same individual


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This IRS article has me a bit confused on what filing is required:



$250,000 combined plan assets - Many plan sponsors didn’t know the $250,000 in plan assets is a combined total for all their one-participant plans. Sponsors must file a Form 5500-EZ for each of their one-participant plans when the total assets at the end of the plan year for all one-participant plans they maintain is greater than $250,000. Some plan sponsors incorrectly thought the $250,000 filing requirement was per plan, per participant or per investment.


Let's say a person has two solo 401k plans setup:

1) Sole proprietorship - solo 401k balance of $1,500,000

2) S-Corp - solo 401k balance of $125k.

Both companies have separate EINs and 401k accounts. Since the individual is the sole participant in both plans would they be required to report the smaller account balance on Form 5500-EZ since in aggregate they are over $250k or is it not required since these are two different sponsors and the 2nd account is under the $250k threshold?

If required, would it be wise to file and request late filer relief and pay the fee?

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Thank you for the help so far guys! In this case is the company itself NOT the plan sponsor, but the plan participant? Where things get murky is I've seen people argue since they are different companies/sponsors they would not need to file, where as I was a bit more conservative and was looking at who the participant/beneficiary of these plans is.

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The company is the plan sponsor even if the company is a sole proprietor. If it is a sole proprietor they are required to get an EIN if they haven't before.

If one person owns both companies, then it's a single employer for retirement plan purposes and doesn't matter what the businesses do.

William C. Presson, ERPA, QPA, QKA
C 205.994.4070


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