Jakyasar Posted August 13, 2021 Posted August 13, 2021 Hi DB plan with life insurance that has cash value and 5500-EZ filing. Looking at instructions for 2020 5500EZ/SF. The wording on the instructions is " an insurance company qualified to do business under the laws of a state e.g. investment contracts with insurance companies". Also from 29 CFR 2520.103-1(c)(2)(ii)(C) "investment and annuity contracts issued by any insurance company" I remember a while back instructions were specific about inclusions of insurance cash value on the 5500 forms. Do I need to include the cash value? Thank you
Mike Preston Posted August 13, 2021 Posted August 13, 2021 Trick question? No, but you do need to include the fair market value. You have lots of reading to do.
Jakyasar Posted August 13, 2021 Author Posted August 13, 2021 Not a trick question, trying to find out more, thank you
Mike Preston Posted August 13, 2021 Posted August 13, 2021 Well, you can start with Rev. Proc. 2005-25 and go from there.
Jakyasar Posted August 13, 2021 Author Posted August 13, 2021 Hi Mike Thank you for the reference as I am quite aware of it and have applied the provisions in the past. My question was not about determining the fair market value. Unless I am missing it (reread again), this rev-proc does not provide an answer on whether I should be including the fair market value of the cash value when preparing the assets for 5500 filing. If I recall correctly (old memory fading), many years ago instructions were specific on not to include cash value in the assets for 5500 purposes and then they removed it. Anyway, I will include. This is the first filing for the plan and this is why I am being picky. Thank you for comments.
Bird Posted August 13, 2021 Posted August 13, 2021 I don't think they ever said not to include fmv on the 5500. There is some confusing (to me) language in the instructions about "insurance contracts" that I finally figured out meant insurance or annuity contracts where the insurer is providing/guaranteeing the benefits. So if, say, you bought an immediate annuity paying monthly benefits, that is no longer an asset. Not including "regular" insurance values is illogical - how do you get it "out" of the assets, as an expense? And what if it is surrendered, how does it come back "in" - as a gain? (I've never done a 412(i) plan and never hope to and have no idea if that reporting is different.) Yet I've seen very experienced administrators showing premiums as expenses and not including values. Bill Presson 1 Ed Snyder
Jakyasar Posted August 13, 2021 Author Posted August 13, 2021 Now that my memory is working as bit better (thanks to ASEA symposium), going back in my memory lane, I believe, at one point instructions stated that no cash values to be included (I may be misremembering this) and then IRS removed that language. I did work with 412i plans but luckily had only annuities, phew. I have now decided to include them in the 5500 forms.
Mike Preston Posted August 13, 2021 Posted August 13, 2021 58 minutes ago, Jakyasar said: Now that my memory is working as bit better (thanks to ASEA symposium), going back in my memory lane, I believe, at one point instructions stated that no cash values to be included (I may be misremembering this) and then IRS removed that language. I did work with 412i plans but luckily had only annuities, phew. I have now decided to include them in the 5500 forms. I think you are misrembering.
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