2015 Form 5500 Released (and longer extension was repealed)

2015 Form 5500 Released (and longer extension was repealed)

5500_Form_screen_shotThe U.S. Department of Labor has released the 2015 Form 5500 and related instructions.  Modifications to Form 5500 as well as schedules and instructions for plan year 2015 are described under “Changes to Note” in the 2015 instructions. Examples of these changes include:

IRS Electronic Filing Requirements. On September 29, 2014, the Treasury Department issued final regulations providing that certain filers must electronically file the Form 5500 series returns/reports (including actuarial schedules. Under the regulations, you are required to file a Form 5500 series return/report electronically if you are required to file at least 250 returns of all types during the calendar year that includes the first day of the applicable plan year. Because the IRS may now require certain filers to electronically file the Form 5500 series returns/reports, the IRS is adding questions to the Form 5500 and its Schedules relating solely to IRS compliance issues. However, these new IRS compliance questions are optional for the 2015 plan year.

IRS Compliance Questions (optional for the 2015 plan year)

  • New Lines 4o, 4p 6c, and 6d were added to Schedules H and I. You are encouraged to answer these questions relating to unrelated business taxable income, in-service distributions, and trust information.
  • New Part VII (IRS Compliance Questions) was added to Schedule R (applicable to pension plans) for purposes of satisfying the reporting requirements of section 6058 of the Code. You are encouraged to answer these questions though they are optional for the 2015 plan year.

Schedule MB (applicable to pension plans). The instructions 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 Schedule MB and instructions are also modified 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. As a result of the Multiemployer Pension Reform Act of 2014, the Schedule MB and instructions are further modified to extend the reporting requirements in line 4 for multiemployer plans in critical status to plans in critical and declining status and require that additional information to be reported by plans that have been partitioned or have had benefits suspended.

Schedule SB (applicable to pension plans). The 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.

Form 5500 Final Return/Report for Plans Trusteed by PBGC (applicable to pension plans). The instructions 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.

Pension and welfare benefit plans that are required to electronically file an annual return regarding their financial conditions, investments and operations generally satisfy that requirement by filing the Form 5500 or Form 5500-SF and any required attachments.

Form 5500 Automatic Extension Remains at 2 ½ Months

On December 4, 2015, Congress repealed the Form 5500 extension period that had been increased back in July of this year.  In July, the automatic extension of 2 ½ months was increased to 3 ½ months for plan years beginning in 2016.  This increased extension period has now been repealed and will remain at 2 ½ months.

Under ERISA and the Internal Revenue Code employee benefit plans generally are required to file the Form 5500, ‘‘Annual Return/ Report of Employee Benefit Plan,’’ together with any required attachments and schedules.  The Form 5500 is not a tax return.  It is an informational return, required by and filed with, the Department of Labor (DOL).  It also serves as a disclosure document for plan participants and beneficiaries, and an important source of information and data for use by other Federal agencies.

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