The IRS has issued additional guidance expanding the time-sensitive plan actions that can be delayed. The following deadlines are among those that have been extended to July 15, 2020 for plan sponsors of defined contribution plans, for which deadlines fall on or after April 1, 2020 and before July 15, 2020:
- Distributions of 402(g) excess deferrals, adjusted for earnings
- Distribution of nondeductible employer contributions to avoid the 10% penalty tax
- Distribution of excess contributions (ADP testing) and excess aggregate contribution (ACP testing), plus earnings to avoid the 10% penalty tax for non-calendar year plans.
- Self-corrections of certain operational failures, by the last day of the second plan year following the plan year in which the failure occurred (for those occurring within April 1 through July 14, 2020)
- Annual Form 5000 Filing (Calendar year plans are not impacted at this time as their due date is July 31, 2020)
www.groom.com; April 10, 2020.
www.ptwt.com; April 2020.