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Schedule T

1. Tip: Any plan that is governed by a standardized prototype document can check the box at 3d. The remainder of the Schedule should then be left blank.

2. Tip: Consider all features that require separate coverage testing before checking any box at line 3. All features must fall under one of the exceptions in order to check any of the boxes at line 3.

3. How do I identify which disaggregated portions require coverage testing?
IRS continues to improve both the instructions and the format of Schedule T, Qualified Pension Plan Coverage Information. The format change this year appears at line 4e, with specific lines provided to insert either a ratio percentage or the exception code. In addition, a new example appears on page 57 of the official instructions to clarify that all disaggregated portions must be reported each year, whether or not there is any activity in that portion for the year. For example, three separate coverage test results must be reported for a profit sharing plan with elective deferral and matching contribution features even if no profit sharing contribution or forfeiture allocation occurred during the plan year (and the plan reports code 2E at line 8a of Form 5500).

Once again, a cross reference may be made to the feature codes reported at line 8a of Form 5500. For example, the following each require separate coverage testing:

2E -- profit sharing
2J -- 401(k)
2K -- 401(m)
2O or 2P -- ESOP

4. If the plan uses the Average Benefits Test to satisfy coverage, must the ratio percentages be shown on lines 4c through e?

Yes. Ratio percentages are likely to be less than 70% in these cases.

5. Tip: Do not attach more than one Schedule T if reporting for a single employer plan. Additional coverage data should be reported on attachments providing the information in the same format as line 4(e) -- no detail is required.
Note: DOL reformatted lines 3 and 4 for the 2001 plan year filings; hopefully, this will make it easier to understand how to complete Schedule T.


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