Santo Gold Posted March 17, 2021 Posted March 17, 2021 We have a 401k plan that was merged into another plan towards the end of the plan year (calendar year). The merger date was 12/15. The last 401k contributions were deposited into the new plan as was the full employer contribution for the plan year. Preparing the final 5500 for the old plan, would you report either that final 401k contribution as part of the overall contributions in the old plan? Same with the employer PS? Thanks
Lou S. Posted March 17, 2021 Posted March 17, 2021 Do the plans file on a cash or accrual basis? Were the post merger deposits contributions for the old plan or new plan?
Santo Gold Posted March 17, 2021 Author Posted March 17, 2021 The plan has been reporting on an accrual basis. The post merger deposits were for the old plan.
Santo Gold Posted March 18, 2021 Author Posted March 18, 2021 The plan has been reporting on an accrual basis. The post merger deposits were for the old plan.
Santo Gold Posted March 18, 2021 Author Posted March 18, 2021 Realized there is another question: On the 8955-SSA, would you now show all previously reported terminated/vested participants as paid out on the final 5500?
Bird Posted March 18, 2021 Posted March 18, 2021 9 hours ago, Santo Gold said: On the 8955-SSA, would you now show all previously reported terminated/vested participants as paid out on the final 5500? Well now that's a confusing question. (My bold - the 8955 and 5500 are different forms.) You should report them as no longer being entitled to benefits on the 8955 for the old plan, and add them on an 8955 for the new plan. I'll assume you didn't mean to say anything about the 5500 itself. Ed Snyder
Santo Gold Posted March 18, 2021 Author Posted March 18, 2021 Yes, I meant to keep the question on the 8955, not the 5500. Thanks
BG5150 Posted March 18, 2021 Posted March 18, 2021 1 hour ago, Bird said: You should report them as no longer being entitled to benefits on the 8955 for the old plan, and add them on an 8955 for the new plan. Give them Code C in the new plan and D in the old plan. Code C Use this code for a participant previously reported under the plan of a different plan sponsor and who will now be receiving a future benefit from the plan reported on this form. Also, complete columns (b), (c), (h), and (i).Code D Use this code for a participant previously reported under the plan number shown on this form who is no longer entitled to those deferred vested benefits. This includes a participant who has begun receiving benefits, has received a lump-sum payout, or has been transferred to another plan (for example, in the case of a plan termination). Also, complete columns (b) and (c). Participants should not be reported under Code D merely because they return to the service of the plan sponsor. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Belgarath Posted April 12, 2021 Posted April 12, 2021 Revisiting this with a slightly different question. Page one of the 8955-SSA instructions, final paragraph in left-hand column on first page, says that you have to report deferred vested benefits if they were previously reported as deferred vested benefits on another plan's filing if their benefits were transferred (other than in a rollover) to the plan of the new employer during the covered period (using Entry Code C in Part III, line 9, column (a);... So: How do you know if they were previously reported on another plan's filing? Do you simply assume that they were reported, and do your filing anyway? Are you obligated to inquire? (P.S. - or do you just use the Code A)? Also, by "rollover" I assume they also mean a direct rollover at the request of the participant? I don't see how it could be otherwise.
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