IR-2021-179 Tax Relief for Ida victims

Hi

If anyone saw this, did you notice anything on pensions i.e. extension for 5500 and also 9/15 contribution dates? I browsed quickly.

In the past they were specific (Sandy etc).

IRS: Tax relief now available to Ida victims in New York and New Jersey; Oct. 15 deadline, other dates extended to Jan. 3 | Internal Revenue Service

Would those fall under the CAA's mandatory (and automatic) 60-day IRS extension for all federally declared disasters? 

Regulations finalized in June list the items covered:  https://www.federalregister.gov/documents/2021/06/11/2021-12311/mandatory-60-day-postponement-of-certain-tax-related-deadlines-by-reason-of-a-federally-declared

Hi Lois

Thank you for the link but I am not 100% convinced.

I did a quick read and there are some references to pensions related sections 7805((A)(d)(4) and unless I am misreading (with a high possibility), this section is at best ambiguous or not included. If you do a search under "pension", you will get a few hits, too many to disclose here.

I would like to hear what others will say/comment.

This is the Rev. Proc. that lists the time-sensitive actions that are extended (the 5500 is one of them): https://www.irs.gov/pub/irs-drop/rp-18-58.pdf

Thank you for this.

I do not see anything regarding minimum funding deadline extension unless I missed it.

Hi All

As I do not see any comments on the minimum funding yet, here are couple additional scenarios. I am just curious and see what/if I missed anything in the law that is always applicable for disaster areas (I live/work in one and that is why I am trying to learn this stuff)

This is for a calendar plan situations.

Scenario 1:

If (and that is a big if) the 2020 minimum funding deadline is extended under the relief (I am not convinced), under SECURE, does that mean a plan sponsor can set up a new defined benefit plan, say in November, and fund/deduct it for 2020 rather than 9/15/2021?

Scenario 2: How about if the sponsor wants to set up a profit sharing plan for 2020, can they do that in November?

Scenario 3: The sponsor wants to set up 401k/safe harbor plan for 2021 (deadline is 10/1/2021). Can they do that for 2021 in November?

Again, just curious and learning.

Thank you all.

I had the same question.  I see that the extension applies to the Form 5500, but does it also apply to the contribution funding?

Not that I have seen nor anyone chimed in. I am having all my clients making their deposits by 9/15 even if their return is extended. no headaches, no issues.

I am also going to have them file their 5500 forms by 10/15.

But that is me.

Yes for 404. No for 412/430. At least based on what you posted.

So, for any calendar plan, 412/430 funding is still due today, at least to my understanding. Any profit sharing can be done later.

4 hours ago, Jakyasar said:

So, for any calendar plan, 412/430 funding is still due today, at least to my understanding. Any profit sharing can be done later.

In addition to Profit Sharing contributions being extended, it appears that a DB plan that has a zero minimum required contribution and a maximum of 126,658, can make a contribution up to the 126K maxium by January. As the maximum is based on 404. 

Yes but can it be reflected on 2020 SB and 2021 AFTAP which need to be certified by 9/30/2021? Unless I am mistaken/missing anything, no.