"Tax Talk" - Summer 2020
As the COVID-19 crisis continues to impact our communities, ABG Southwest is ready to help in any way we can, from discussing retirement plan participation and trends to highlighting approaching deadlines. In this issue of Tax Talk, we provide some important compliance due dates for defined contribution plans and noteworthy new provisions from the IRS.
Upcoming Compliance Deadlines
September 15, 2020
- Deadline for money purchase pension, target benefit and defined benefit plans to make required contributions to their plan trust, and for sponsors that filed a corporate tax extension to make 2019 employer profit-sharing and matching contributions.
- Minimum funding deadline for pension plans.
- Form 5500s are due to the Employee Benefits Security Administration (EBSA) from plans eligible for an automatic extension linked to a corporate tax extension.
September 30, 2020
- Summary annual reports are due to participants from plans with a December 31 year-end.
October 1, 2020
- Start of the period to disseminate annual notices to participants, including the 401(k) safe harbor, automatic contribution arrangement (ACA), qualified automatic contribution arrangement (QACA) safe harbor, and qualified default investment alternative (QDIA)—i.e., from 90 to 30 days prior to the end of the current plan year.
New & Noteworthy
In June, the IRS announced that anyone who has taken a required minimum distribution (RMD) in 2020 has the opportunity to roll those funds back into a retirement account, in keeping with the CARES Act RMD waiver for 2020:
- The 60-day rollover period for any RMDs already taken this year has been extended to August 31, 2020.
- Details of this new provision are provided in IRS Notice 2020-51.
The IRS also provided temporary administrative relief to help plan participants or beneficiaries, who need to make participant elections, sign remotely without requiring the physical presence of a plan representative or notary as witness:
- The guidance accommodates local shutdowns and social distancing practices and is intended to facilitate the payment of coronavirus-related distributions and plan loans to qualified individuals, as permitted by the CARES Act.
- The IRS provides additional guidance in IRS Notice 2020-42.
We Welcome Your Questions
As always, we are standing by to support you and your employees in this unprecedented time. Please contact your ABG Southwest primary relationship manager for additional information or assistance in meeting some of these important deadlines.
Challenging times require making tough decisions, quickly. You can count on us to keep you briefed on new funding sources, compliance updates, planning resources and more essential updates regarding the COVID-19 crisis. Access REDW’s COVID-19 Resource Hub.