"Assume that a company missed 5 years of 5500 filings and is preparing to submit them through DFVCP. The auditor has explained that in cases like this, it is their practice to only file the 8955 for the most recently missed 5500 filing, since the prior data is 'outdated' by the form is filed. Thought on this approach? I don't see this as acceptable."

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"Might be inheriting 2 existing plans for 2025, one has top-paid and one has lookback definition for HCE determination. Too late to change anything for 2025. Did some research on BL and also Notice 97-45, not sure I located the answer but looks like I can only use 'lookback' method. Will be amending to match during 2026. Any comments or cites are appreciated."

"Is there an issue with an S-Corp claiming the profit-sharing deduction and filing their return but not actually contributing the profit-sharing until after the tax return has been filed? Could this be applied to other areas, such as an individual claiming an IRA deduction for the previous year. Filing their taxes but not contributing the money until after their taxes are filed but before the tax deadline?"

"Client gets a notice from the IRS that Form 945 was not filled out for plan years 2022 and 2024. As a TPA, we do not do this, their recordkeeper (VOYA) does not do it. Their tax person advised them to follow up with their 'plan administrator' (meaning us) but technically THEY are the plan administrator so someone in their company should have done it. Why would they not know this. Anyone else run into this issue?"