DB Plan termination, when is withholding due?

A one-participant DB plan terminated in December 2020.  Participant received full distribution on 12/22/20, amount in excess of 2 million.  Read the instructions for Form 945 and Publication 15.  Pub 15 refers to filing for Form 941.  If we use that, and the lookback period was zero, is the client a semiweekly filer?  Or does the next day filer rule apply?

Does it matter at this point (Jan 13) or are you just trying to figure out the penalties?

And someone took $2M in cash?!

Not having looked at it in a while, I'm leaning towards next day filer, but am not sure.

Totally unhelpful, sorry!

Thanks, Bird!  The participant received payments from the assets of the plan on two different days; each in a different deposit period, but both over the $100K limit.  (Yup, took it all in cash!)  I think both would be subject to the next day filing requirement.  At this point, the CPA had said he needed to set up an account for the plan to submit the withholding taxes.  (We did tell the client and CPA they needed to get that done in December.)  

If they get an IRS notice on penalties for late filing, will have them complete Form 843 to request abatement.  Absolutely no intent to willfully neglect paying this.

Interesting.

I wonder if the participant figured that income tax rates might increase substantially in 2021, so decided to take on the income taxes in order to take advantage of the historically low rates in the 2020 taxable year.

One year I had a client take a large taxable distribution on plan termination, not 2M but high 6 figures, because he had losses to off set all or nearly all the income. So you never know what a participant's tax situation might be unless you are their CPA. Maybe with COVID they have large 2020 losses elsewhere they can apply against the DB distribution somehow. Just speculating, I'm not a CPA.

But on the initial question I'm with Bird based on the size of the withholding.