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2023 Start up plan 5500 audit requirements


MicheleH

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I've not had much luck finding an answer to this, hoping the contributors here can help me - with the change in methodology of participant count for the 2023 Form 5500, now looking at participants with a balance as of the beginning of the year, how will this impact new plans that have 0 participants with a balance as of the beginning of the year but over 100 at the end? I found one line from Ascensus that stated a first year filing would look to participants with a balance on the last day (which makes sense to me, otherwise all new plans would be small filers). However, I can't find that stated on any governmental site. Has anyone looked into this or have a link to postings from the IRS/DOL? 

Thank you!

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See the rule published at 88 FR 12048 (page 65 of the pdf here: https://www.govinfo.gov/content/pkg/FR-2023-02-24/pdf/2023-02653.pdf)

DC plans use the number of participants with a balance as of the first day of the year to determine if they are a small plan or a large plan, unless they check the box for first return/report, in which case they use the number of participants with a balance as of the last day of the year.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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