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Single member plan terminated, liquidated 11/23/2021... File 2020 EZ now?


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Posted

A client closed down her single member plan and it's final liquidation occurred on 11/23.  The balance is $0.  My next step is to prepare a final form 5500-EZ.  

Do I  use the 2020 EZ?  and change the year end to be 11/23/2021?

Just want to do it correctly, cross the T's and dot the I's

Thanks

Posted

I'd just do it on December 1.  Make PYE 11/30/21.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

So what I am gathering is that to do it right I would prepare a form 5500-EZ now using a 2020 form, make the PYE say 11/24 and file it.  Sound right?

 

Posted

The Form 5500-EZ Instructions support what Bill Presson says:  “For a short plan year, file a return by the last day of the 7th month following the end of the short plan year.  Modify the heading of the form to show the beginning and ending dates of your short plan year and check box A(4) for a short plan year.  If this is also the first or final return filed for the plan, check the appropriate box (box A(1) or A(3)).”  https://www.irs.gov/pub/irs-pdf/i5500ez.pdf

But for an information return one may choose to file by mailing paper, is there anything that precludes an employer/administrator from filing soon after the plan year ended?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

Peter, I don't think there's anything that says they couldn't file on 11/24.

I just like round numbers.

And just like that, tomorrow is December 1.

And tot he OP, you do file on a 2020 form but just update the plan year.  Talk to your software vendor on how to do that.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

Yup, we concur.  I've done a Form 5500 report as quickly as the morning after the transaction that made the plan's assets zero.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted
On 11/30/2021 at 4:31 PM, BG5150 said:

And to the OP, you do file on a 2020 form but just update the plan year.  Talk to your software vendor on how to do that.

Thanks!  I am of the mind to file it now before it slips through the cracks.

Just for my own knowledge, I would use a 2020 form because the plan would be a short year ending before December 31, 2021?

Posted

You would use the 2020 form because the 2021 form is not available yet. If you wait a month or so, the 2021 5500-EZ will probably be available and then you would need to use that.

Speaking of the 2021 5500-EZ, I seem to remember that the IRS actually did publish it a couple of months ago, but it seems to have disappeared from the internet.

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

Posted

You can and must use 2021 forms if passed 12/31/2020 deadline to file. If the rule changed, do not know but it has been for a long time.

Posted
21 hours ago, Jakyasar said:

You can and must use 2021 forms if passed 12/31/2020 deadline to file

Ohh.. ok.  The plan has been liquidated, the 1 employee has been paid out so I will file now.  

Just to recap:

  • If I file before 12/31/2021 I use the 2020 form 5500-EZ
  • If I file in 2022 I would use the 2021 form 5500-EZ
  • The year end on the form regardless of the form's year would  be the day the plan was 100% liquidated, 11/24/2021
    (I wouldn't put the year end 12/31/2021)

Thanks to all for chiming in.  My goal is to understand the proper/correct way to complete what I am sure to many are things that are ingrained. I'm a firm believer that it can't hurt to ask.  

Posted

I don't think the last day of the plan year matters much if it's w/in a couple days.

I always just use the end of the month that the last withdrawals happened.  Again, I like the round numbers.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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