"We have a few Plans that were adopted in February or March of 2026, as of December 31, 2025 (as allowed under Secure 2.0). Should we be filing extensions and Form 5500 for these Plans? I know under Section 201 of Secure 2.0 it technically isn't required, or is that just for Plans adopted after the extension date? I don't want to miss anything, or file an extension if we aren't supposed to."

"Our company is terminating its frozen pension. A favorable determination letter was received after filing a form 5310. However, the TPA we utilized noticed that two amendments were necessary. We amended the plan to update it for the SECURE 2.0 changes with respect to RMD ages. In addition, the plan was amended to clarify lump sum window language with respect to the death of an eligible individual who dies prior to their annuity start date. Does anyone know whether there is a requirement to start the process over with a new determination letter or amend the process? Or, are these changes insignificant to the tax qualification status of the plan and the determination letter still suffices?"

"Current understanding is that for plan corrections there must be a Procedure and Practices document in place. What resource are practitioners using as an example/sample document? and where is the document available?"

"A married couple divorces. They reach a marital settlement agreement providing for the entry of a shared interest QDRO under a defined benefit plan. Based solely upon the terms of the settlement agreement, the plan's administrator proposes to implement a determination of the shared interests of the parties, which is driven by the fact that the participant is about to retire. May the plan's administrator appropriately determine the separate interests of the parties prior to the court's entry of the DRO and the plan administrator's determination that such order is qualified?"

"A client is terminating an individually designed defined benefit pension plan. We are unable to find signed copies of a 2017 amendment (or corporate resolutions reflecting the adoption of the amendment) related to the addition of optional forms of distribution (i.e, not an amendment to update the plan for legal changes). The Plan has been operated in compliance with the amendment since it was 'adopted.' We are planning to file a Form 5310 for the termination. Any thoughts on how the Service might handle the missing signature? Even if we wanted to file a VCP request, it would not be resolved in time to file the Form 5310."

"So things are different and you no longer file Form 5558 to file extension on Form 5330. Unclear to me that if you don't yet know the amount of lost earnings, how do you enter an amount to pay with Form 8868? Seems it does not accept zero."

"Can an employee and their spouse enroll in each of their employer's HDHP and cover each other? For example, an employee elects a HDHP under their employer's health plan and receive HSA employer contributions; Meanwhile, the spouse also enrolls in her employer's HDHP Health plan covering both of them, but does not contribute to her HSA, nor does the employer contribute. My understanding is that dual coverage is allowed as long as both are HDHPs and they don't exceed the irs limit of $8,750 in HSA contributions. Is this correct?"