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How to Show on Form 5500 That a Welfare Benefit Plan Is Going Above or Dropping Below the 100-Participant Threshold
Thomson Reuters / EBIA Link to more items from this source
July 5, 2018
"Plans going under and over the threshold like this should not, in Part I of the main body of the Form, check the 'final return/report' or 'first return/report' boxes on line B. And do not confuse this exemption with the so-called '80-120' rule, which permits a plan that is not exempt from filing Form 5500 to continue filing the same financial Schedule (Schedule H for large plans or Schedule I for small plans) so long as it has at least 80 covered participants but not more than 120."

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