By: Kristina Kananen, APA, QPA, QKA, DATAIR Employee Benefit Systems, Inc.
In a stunning reversal, the IRS is issuing new instructions for the 2015 5500 Series and the 2015 5500-SF as they pertain to the new IRS Compliance questions. All instructions for these items in the new version have been changed to read:
The IRS has decided not to require plan sponsors to complete this question for the 2015 plan year and plan sponsors should skip this question when completing the form.
This change is in effect for the following new questions:
Preparer Information on Form 5500 and Form 5500-SF
Schedules H and I
Lines 4o, Unrelated Business Taxable Income
Lines 4p, In-Service Distributions
Part V, Lines 6a-d, Trust Information
Part VII, Lines 20a-c, 21a-b, 22a-c, 23
Line 10j, Unrelated Business Taxable Income
Lines 14a thru 14d, Trust Information
Part IX, Lines 15a-c, 16a and b, 17a-d, 18, 19 and 20
If you have already filed 2015 filings in which you completed these questions, those filings will stand and the information you provided will be made public and provided to the IRS. Future filings that you prepare for 2015 plan years, should be prepared with the “should skip” instructions in mind.
It is believed that after many comments from the qualified plan industry regarding the first set of 2015 5500 Series instructions and the new IRS questions, the IRS is revamping their questions and the instructions. Those changes and clarifications will be probably be seen in the 2016 5500 Series.