short plan year and availability of form 5500 or 5500EZ

Hi, 

Probably a very simple question, but I couldn't find any guidance.   If the plan was closed and distribution was done early in the year, say March 2018, and you need to file 5500 for the short plan year of 2018, which year 5500 form should you use? I asked this because it seems you should use the year 2018 form 5500, but the year 2018 form 5500 will not be available until the early months of 2019.   Can you just use the year 2017 form 5500 for the short 2018 plan year? 

You use the "2017" form and change the year beginning and ending dates.

taking it one step further. let's say everything was paid out 1/31/2018.

without extension the forms are due 8/31/2018

with extension they are due 11/15/2018

if the 2018 forms weren't released until 2019 you would be unable to file and meet the filing deadline. so you are permitted to use the prior year form.

The instruction for the 5500 indicate (this is form a few years ago, but the same rule applies)

(2) If the 2015 Form 5500 is not available before the plan or DFE filing is

due, use the 2014 Form 5500 and enter the 2015 fiscal year

beginning and ending dates on the line provided at the top of the form

.............................

with FT William you have to create an 'extra' plan form or duplicate plan form or whatever it is called. so you would end up with a plan year end 12/31/2017

and then another with the correct dates, but on a 2017 form.

A caution on using the prior year forms for a 2017  short year/final filing:  You must complete the filing by midnight EST on 12/31/17 for a 2017 (signed and transmitted to EFAST).  Failure to do so means you will have to start over on 1/1/18 as EFAST will not accept the filing after 12/31/17 and complete the 2017 forms for the 2017 short year/final filing