March Compliance Deadlines, Climber trying to reach the top

March Compliance Deadlines for Retirement and Other Benefit Plans

March 5, 2021

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Compliance deadlines for retirement, health and welfare benefit plans are coming up fast with a half dozen already passed. Thank you IslerDare PC for providing us this update to share.

Two Passed Compliance Deadlines:

March 1

  • File DOL[i] Form M-1 for MEWAs[ii] and complete online disclosure to CMS[iii] regarding “creditable coverage” status for prescription drug coverage to Medicare Part D individuals

By March 2

  • Deadline to provide 2020 ACA[iv] information returns to individuals (extended from January 31) to satisfy IRS requirements and deadline for select state mandates including New Jersey and Rhode Island employers to distribute ACA information returns to individuals to satisfy requirements regarding state individual mandate 

Upcoming Compliance Deadlines You Can Still Make

By March 15

  • Deadline to apply to the IRS for a waiver of the minimum funding standard for defined benefit and money purchase pension plans
  • Process corrective distributions to “cure” failed 2020 ADP/ACP[v] tests for 401(k) plans to avoid paying 10% excise tax (a later June 30 deadline applies to 401(k) plans with eligible automatic contribution arrangements)
  • Fund all 2020 company contributions to retirement plans by due date for corporate tax return in order to deduct contributions for 2020 tax year (unless Form 7004 has been filed to extend due date for corporate tax return, permitting funding by September 15)
  • Deadline to adopt defined benefit pension plan amendments for the prior year for funding purposes
  • File Form 8928 to report excise taxes for noncompliance with certain group health plan requirements (unless Form 7004 has been filed to extend due date for corporate tax return, permitting filing by September 15)

By March 31

  • Receive elections from eligible ESOP participants to diversify a portion of their ESOP[vi] accounts
  • Confirm retirement plan recordkeepers have filed Forms 1099-R, if filing electronically
  • File ACA information reporting returns for 2020 with the IRS, if filing electronically
  • File Form 5330 to report and pay excise taxes for excess 2019 plan year ADP/ACP contributions that were not timely corrected in 2020 (or file Form 5558 to request extension of up to six months to file)
  • File Retiree Drug Subsidy (RDS) reconciliation with CMS for 2019
  • Deadline for California employers to submit ACA information returns to the California Franchise Tax Board to satisfy California individual mandate requirements
  • Deadline for New Jersey employers to submit ACA information returns to the New Jersey Division of Revenue and Enterprise Services to satisfy state individual mandate requirements
  • Deadline for Rhode Island employers to submit ACA information returns to the Rhode Island Department of Revenue, Division of Taxation to satisfy state individual mandate requirements
  • Deadline for Massachusetts employers to submit HIRD and Form 1099-HC electronically through the MassTaxConnect web portal to satisfy state individual mandate requirements
Natural fern in forest with penetrating sun rays

[i] DOL Department of Labor

[ii] MEWAs Multiple Employer Welfare Arrangements

[iii] CMS Centers for Medicare & Medicaid Services

[iv] ACA Affordable Care Act

[v] ADP/ACP Actual Deferral Percentage (ADP) and Actual Contribution Percentage (ACP)

[vi] ESOP employee stock ownership plan

This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, accounting, legal or tax advice. Any tax advice contained herein is of a general nature. You should seek specific advice from your tax professional before pursuing any idea contemplated herein.

Securities offered through Lion Street Financial, LLC (LSF) and Valmark Securities, Inc. (VSI), each a member of FINRA and SIPC. Investment advisory services offered through Lion Street Advisors, LLC (LSA) and Valmark Advisers, Inc. (VAI), each an SEC registered investment advisor. Please refer to your investment advisory agreement and the Form ADV disclosures provided to you for more information. VAI/VSI and LSF/LSA are non-affiliated entities and separate entities from OneDigital and Fulcrum Partners.

Unless otherwise noted, VAI/VSI, LSF/LSA are not affiliated, associated, authorized, endorsed by, or in any way officially connected with any other company, agency or government agency identified or referenced in this document.

Lion Street Advisors // Lion Street Financial

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