IRS Invites Comments on Changes to 2016 Forms 5500 and 5500-SUP

The IRS on March 31 invited comments on changes that have been proposed to the Form 5500 and several of its schedules, as well as the Form 5500-SUP, for information reporting concerning the 2016 plan year.

Changes include the following:

Question 3: Revisions to the information requested after answering question 3(a), which concerns whether the plan is a 401(k) plan. Affects Form 5500, Schedule R, Form 5500-SF and Form 5500-SUP.

Question 4: Revisions to the question concerning the method by which a qualified plan satisfied the minimum coverage requirements on employee participation. Affects Form 5500, Schedule R, Form 5500-SF and Form 5500-SUP.

Question 5: Revisions to the question concerning the identification of whether distributions to employees are being made before otherwise permissible in a defined benefit or money purchase plan. Affects Form 5500, Schedules H and I, Form 5500-SF, Form 5500-EZ and Form 5500-SUP.

Question 6: Question concerning whether a plan trust incurred unrelated business taxable income deleted for 2016. Affects Form 5500, Schedules H and I, Form 5500-SF, Form 5500-EZ and Form 5500-SUP.

Question 7: Revisions that simplify and shorten the question concerning whether and when a plan received a favorable opinion letter, advisory letter or determination letter from the IRS. Affects Form 5500, Schedule R, Line 23a; Form 5500-SF, line 17a; Form 5500-SUP, Line 6a; and Form 5500-EZ, Line 13a.

Question 8: Revisions that simplify and shorten the question that identifies plans to which special rules apply that require minimum distributions to a participant regardless of whether he or she continues in employment. Affects Form 5500-SF and Form 5500-EZ.

The IRS is inviting comments on:

• whether the collection of information is necessary for the IRS to performance its functions, including whether the information shall have practical utility;
• the accuracy of the IRS’ estimate of the burden of the collection of information;
• ways to enhance the quality, utility and clarity of the information to be collected;
• ways to minimize the burden on respondents of the collection of information, including through the use of automated collection techniques or other forms of information technology; and
• estimates of capital or start-up costs and costs of operation, maintenance and purchase of services to provide information.

Comments are due by May 31 and should be sent to:

Tuawana Pinkston
Internal Revenue Service
Room 6129
1111 Constitution Avenue NW
Washington, DC 20224