Upcoming Employee Benefit Plan Deadlines
This law alert follows up on our prior alerts entitled "Employee Benefit Plan Filing Deadlines." The following are the most common applicable filing deadlines (and/or "Heads Up" for coming deadlines) or other important dates for May, June and July 2016 for calendar year plans:
May 15 – Deadline for a plan administrator to distribute benefit statements for the second quarter to participants who have participant-directed accounts in a defined contribution plan.
May 15 – Deadline for a plan administrator for disclosing plan fees and expenses deducted from individual participant accounts in a defined contribution plan that has participant-directed accounts. Note that this can be done in the benefit statement described in the preceding deadline or as a standalone document.
May 15 – Deadline for tax-exempt trusts associated with qualified plans or VEBAS to file Forms 990 or 990-EZ with the IRS for the 2015 year, unless a three month extension is requested by filing a Form 8868 by this date.
May 31 – Deadline for Forms 1094-B and 1094-C to be filed with the IRS if filing paper forms. Note the later deadlines below if filing electronically.
June 30 – Extended deadline for large employers to file a copy of the Forms 1094-C with the IRS if filing electronically.
June 30 – Extended deadline for small employers who provide a self-insured health plan (or health insurance carriers if the plan is insured) for employees to file a copy of the Forms 1094-B with the IRS if filing electronically.
June 30 – Deadline for a plan sponsor for processing corrective distributions for a failed ADP/ACP test from a 401k plan with an eligible automatic contribution arrangement (EACA) that covers all employees to avoid a 10 percent excise tax.
July 15 – Deadline for a plan sponsor to make the second quarter contribution for applicable defined benefit pension plans for the 2016 plan year.
July 28 – Deadline for a plan administrator to provide a summary of material modifications to participants and beneficiaries receiving benefits for modifications adopted to employee benefit plans during the 2015 plan year.
July 31 – Deadline for a plan sponsor of a self-insured group health plan (insurers report and pay fees for insured group coverage) to pay Patient-Centered Outcomes Research Institute Fees (“PCORI Fees”) with respect to the plan year ending in 2015 by filing a Form 720 with the IRS. Note the fee is $2.08 or $2.17 per covered life depending on the last month of the plan year for the plan.
July 31 – Deadline for a plan sponsor of qualified plans and health and welfare plans to file Forms 5500 with the IRS, unless an extension of time (of two and one half months) has been requested before this deadline by filing a Form 5558 with the IRS.
July 31 – Deadline for a plan sponsor of qualified plans to file a Form 8955-SSA to report certain information relating to each participant with a deferred vested benefit, unless an extension has been obtained by filing a Form 5558 with the IRS.
July 31 – Deadline for a plan sponsor of qualified plans to provide a notice to each separated participant providing information about the participant’s deferred vested benefit as filed on its Form 8955-SSA, unless an extension has been obtained by filing a Form 5558 with the IRS.
July 31 – Deadline for a plan sponsor to file a Form 5330 with the IRS for excise taxes related to employee benefits plans–for example, late test corrections or late deposits of employee deferrals unless an extension applies.
Please note that there are other deadlines which apply to the distribution of documents and notices to employees upon their employment or their termination of employment which are not addressed in this alert. If you have any questions regarding the deadlines listed in this alert or any other compliance deadlines, please contact Donald S. Kohla at 678.336.7140 or Jan G. Marsh at 678.336.7135.
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