2015 Form 5500 annual return/report series issued

The Employee Benefits Security Administration (EBSA), the IRS, and the Pension Benefit Guaranty Corporation (PBGC) have issued advance informational copies of the 2015 Form 5500 annual return/report, related instructions and schedules, and 2015 Form 5500-SF and instructions. The advance copies cannot be used to file a 2015 form.

Electronic filing requirement

Under final regulations issued in September 2014, certain plan administrators and employers maintaining retirement plans are required to file electronically the Form 5500 series. Under IRS Reg. §301.6058-2, a Form 5500 series return must be filed electronically if the plan administrator and the employer maintaining the plan are, in the aggregate, required to file at least 250 returns of all types during the calendar year that includes the first day of the plan year. For Form 5500 series returns, the electronic filing requirements apply to returns that must filed for plan years that begin on or after January 1, 2015, but only for filings with a filing deadline (not taking into account extensions) after December 31, 2015.

The IRS has added questions to 2015 Forms 5500 and 5500-SF relating solely to IRS compliance issues that are optional for the 2015 plan year. However, the IRS encourages filers to answer the questions. The IRS added questions to Schedules H and I (Lines 4o, 4p, 6c, and 6d) and Schedule R (Part VII), and to the Form 5500-SF (Lines 10j, 14c, 14d, and Part IX) for purposes of satisfying the reporting requirements of Code Sec. 6058. The questions cover issues concerning, among other things, unrelated business taxable income, in-service distributions, trust information, 401(k) nondiscrimination requirements, plan amendment/restatement information, and favorable opinion or advisory letter and determination letter information.

Schedule MB

The instructions for Schedule MB are modified to add RP-2000 and RP-2000 (with Blue Collar Adjustment) to the list of mortality tables for non-disabled lives that plans may report in line 6c. The IRS has changed Schedule MB and instructions to add a new question in Line 8b that would require large multiemployer plans (500 or more total participants as of the valuation date) to provide in an attachment a projection of expected benefit payments to be paid for the entire plan (not including expected expenses) for each of the next ten plan years starting with the plan year to which the filing relates.

The Schedule MB is modified to require all multiemployer plans to report the funded percentage for monitoring the plan’s status in Line 4. Previously, only plans in critical or endangered status were required to report this information. Finally, the Schedule MB and instructions are modified to extend the reporting requirements in Line 4 for multiemployer plans in critical status to plans in critical and declining status and to require that additional information be reported by plans that have been partitioned or have had benefits suspended.

Schedule SB

The Schedule SB instructions are modified to simplify the alternative age/service scatters that cash balance plans with 1,000 or more active participants have an option to report on an attachment to Line 26.

Final 5500s for PBGC-trusteed plans

The Form 5500 instructions for “Final Return/Report” and the Form 5500-SF instructions for “Line B – Box for Final Return/Report” are modified to add a statement that a filer for a terminated defined benefit plan for which PBGC has been appointed trustee may contact DOL at PBGCTrusteedPlan@dol.gov for further information.

FAQs

The IRS has also issued frequently asked questions (FAQs) that provide clarification on some of the new compliance questions, including 401(k) nondiscrimination requirements, unrelated business taxable income, in-service distributions, trust information, and plan amendment/restatement information. The FAQs are at https://www.irs.gov/Retirement-Plans/Frequently-Asked-Questions-Regarding-the-IRS-Compliance-Questions-on-the-2015-Form-5500-Series-Returns.

Source: 2015 Form 5500 series.

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