Corporate contributions to DC Contributions

Questions re due date for corporate contributions to DC plans:

• We know corporate contributions now due 15th of 4th month (04/15 for calendar year).  Does this apply to both S Corps and C corps?
• Does extension now extend them to 10/15?
• We have plan with fiscal YE 05/31/19.  This means we file 2018 version of 5500s.  I can't find anything that tells me when that contribution is due - would it be 02/15/20 (old rules) or 03/15/20 (new rules)?
• Exactly when was this change effective?

I am just having a lot of history researching it to find out the history.  Everything I find just addresses current rules. Thanks for the help.

For a 12/31 pye  S Corp 3/15 extended to 9/15   not changing.   C Corp 3/15 extended to 9/15.  Change  not until 2025/2026.  I have a chart. If you want me to email it to you message me your email - I can do it on Monday!

Contributions must be made no later than the sponsor's tax filing deadline (including extensions) in order to be deductible for that tax year.

Contributions made no later than 30 days after the tax deadline (including extensions) can be considered annual additions for the plan year.

So you can have a situation where, say your tax deadline is March 15, 2019, you make a contribution on March 20, 2019, and count it as an annual addition for the 2019 plan year, but deduct it on your 2020 tax return and apply it against the 2020 deduction limit, which is in turn based on plan year 2020 participant compensation.

The safest (and simplest) method, and what I generally tell my clients, is always to have the contributions in before the tax deadline, or better yet before the tax return is filed.

If the tax year is different from the plan year, then it gets more complicated.

18 hours ago, Cynchbeast said:

Questions re due date for corporate contributions to DC plans:

• We know corporate contributions now due 15th of 4th month (04/15 for calendar year).  Does this apply to both S Corps and C corps?
• Does extension now extend them to 10/15?
• We have plan with fiscal YE 05/31/19.  This means we file 2018 version of 5500s.  I can't find anything that tells me when that contribution is due - would it be 02/15/20 (old rules) or 03/15/20 (new rules)?
• Exactly when was this change effective?

I am just having a lot of history researching it to find out the history.  Everything I find just addresses current rules. Thanks for the help.

Your first statement is incorrect; you have different rules for different types of entities now.

For calendar year entities:

S Corp return due 3/15; extension takes it to 9/15 (which is same as the old rules).

C Corp return now due 4/15; extension takes it to 10/15 (which is a change that makes both dates one month later).

As you can see, the first due dates and the extension date are DIFFERENT for S Corps and C corps.

And for comparison, sole props are the same as C Corps (4/15 and 10/15); Partnerships are the same as S Corps (3/15 and 9/15).

On your third bullet, you are not clear as to what is the fiscal year of the entity nor what kind of entity; that is necessary to answer your question.  Assuming plan and entity have the same fiscal year, if the corp is a S corp, the contribution is due 2 1/2 months after year end (8/15) or extended to 2/15 (new rules, not old rules).  If a C corp, the contribution is due 3 1/2 months after year end (9/15) or extended to 3/15 (new rules).  We don't really care anymore about the old rules now do we?

For your question about when did this change, did you consider goggling "when did due date for tax return for C corp change"?  You might find this:

Tax provisions included in the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, P.L. 114-41 modify the due dates for several common tax returns and certain information returns (W-2 and 1099-Misc). The act set new due dates for partnership and C corporation returns as well as for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), and several other IRS information returns. The changes are effective for taxable years starting after December 31, 2015 (2016 tax returns filed in 2017).

Here's a chart you can refer to:  

https://www.aicpa.org/interestareas/tax/resources/compliance/downloadabledocuments/due-dates-summary-chart.pdf

3 hours ago, ratherbereading said:

For a 12/31 pye  S Corp 3/15 extended to 9/15   not changing.   C Corp 3/15 extended to 9/15.  Change  not until 2025/2026.  I have a chart. If you want me to email it to you message me your email - I can do it on Monday!

I have no idea what your 2025/26 reference is; what does that sentence mean?

1 hour ago, C. B. Zeller said:

 

The safest (and simplest) method, and what I generally tell my clients, is always to have the contributions in before the tax deadline, or better yet before the tax return is filed.

If the tax year is different from the plan year, then it gets more complicated.

No reason for the contribution to be in before the return is filed.  Lots of clients file their return earlier than the due date (or after due date but before extended date) but don't put the money in until after the return is filed and that's just fine.  We just remind them how important it is to get the money in by their due date (whichever one is applicable) or they are going to have to file amended returns AND have other problems as well (plus re-do fees from us for having to redo the annual valuation).

1 hour ago, Larry Starr said:

No reason for the contribution to be in before the return is filed.  Lots of clients file their return earlier than the due date (or after due date but before extended date) but don't put the money in until after the return is filed and that's just fine.  We just remind them how important it is to get the money in by their due date (whichever one is applicable) or they are going to have to file amended returns AND have other problems as well (plus re-do fees from us for having to redo the annual valuation).

Oh, I agree completely, but for a certain type of client it is easier for them to understand simple instructions like "make your contribution before you file your taxes."

On ‎3‎/‎6‎/‎2020 at 1:39 PM, Larry Starr said:

I have no idea what your 2025/26 reference is; what does that sentence mean?

Larry Starr, please see attached chart - you will see the 2025/2026 years referenced.

orig and ext tax due dates.pdf

RBR - the attachment you included was revised again on February 8, 2017. The IRS used its authority to modify the date to October 15th for C-corps, as per the Form 7004 instructions, and the IRS website. Here's the most updated version I have...

https://www.aicpa.org/interestareas/tax/resources/compliance/downloadabledocuments/due-dates-summary-chart.pdf

4 hours ago, Belgarath said:

RBR - the attachment you included was revised again on February 8, 2017. The IRS used its authority to modify the date to October 15th for C-corps, as per the Form 7004 instructions, and the IRS website. Here's the most updated version I have...

https://www.aicpa.org/interestareas/tax/resources/compliance/downloadabledocuments/due-dates-summary-chart.pdf

Thanks!!

On 3/6/2020 at 1:39 PM, Larry Starr said:

I have no idea what your 2025/26 reference is; what does that sentence mean?

6 hours ago, ratherbereading said:

Larry Starr, please see attached chart - you will see the 2025/2026 years referenced.

orig and ext tax due dates.pdf 342.17 kB · 4 downloads

Much better to not use out of date references; our business changes too quickly to use a chart that was set up in January, 2016.

As you now know from the other responder, my original posting of the due dates is correct.