March 15 Employer Contribution Deadline (without extension)

Posted by Aaron Juckett, CPA, CPC, QPA, QKA on Tue, Feb 23, 2010
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The Retirement News for Employers – Winter 2010 Edition provides a reminder that the deadline to make ESOP contributions for a calendar-year filer is March 15. With a valid extension, that date can be extended until September 15:

Deadline for Making Employer Contributions

Employer contributions to a defined contribution (DC) plan can be made until the due date of the employer's tax return, including extensions, regardless of when the tax return is actually filed. For example, a calendar-year corporate income tax return is due on March 15, but, with a valid extension, the corporation has until September 15 to both file its tax return and deposit employer contributions into its DC plan's trust or IRA. If contributions are not deposited timely, the employer must amend its tax return and pay any tax, interest and penalties that may apply.

The employer's DC contributions for a year can be made until the extended due date of the tax return for that year if:

  • the plan was established by the end of the calendar year; and
  • the plan treats these contributions as though it had received them on the last day of the calendar year.

However, a SEP plan sponsor has until the due date of the year's income tax return, including extensions, to both set up and fund the SEP plan for the year.

It also provides some upcoming mandatory deadlines, noting that non-calendar-year plans will need to adjust some of the dates:

  • March 1: Paper Forms 1099-R and Form 1096 for 2009 distributions due to IRS. Benefit Payment Government Filings (IRS Forms 1099-R, 1096, 945)
  • March 15: Application of Waiver for 2009 Minimum Funding Standard for defined benefit plans due.
  • March 15: ADP/ACP distributions of 2009 excess amounts, with earnings, due to highly compensated participants to avoid 10% excise tax (June 30, in the case of certain eligible automatic contribution arrangements.)
  • March 15: Form 1042S, Foreign Person's U.S. Source Income Subject to Withholding, and Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons, due to IRS to report retirement plan distributions and income tax withheld from distributions made to nonresident aliens.
  • March 15: 2009 corporate employer contributions due to take tax deduction (with no corporate filing extension).
  • March 31: Electronic filing of Forms 1099-R for 2009 distributions due to IRS. Benefit Payment Government Filings (IRS Forms 1099-R, 1096, 945)
  • March 31: Last day for sponsors of single employer defined benefit plans to obtain AFTAP certification from enrolled actuary to avoid possible 10-percentage-point decrease in presumed AFTAP.
  • April 1: Sponsors of single employer defined benefit plans that have not received a certified AFTAP from the enrolled actuary should review benefit restrictions under Code §436 to determine whether additional restrictions apply or whether other action is required.
  • April 15: Deadline for returning 2009 participant deferrals, with earnings, in excess of $16,500 ($22,000, if 50 or older).
  • April 15: Deadline to make 2009 traditional and Roth IRA contributions.
  • April 15: First quarterly defined benefit contribution installment due for the 2010 plan year.
  • April 15: 2009 self-employed individual and partnership contributions due to take tax deduction for 2009 (with no filing extension).
  • April 30: Last day to adopt EGTRRA pre-approved defined contribution plans, and submit them for a determination letter, if desired, to the IRS.

Topics: Compliance

Aaron Juckett, CPA, CPC, QPA, QKA
Written by Aaron Juckett, CPA, CPC, QPA, QKA

Aaron is President and founder of ESOP Partners and provides implementation, administration, and consulting services to hundreds of companies. He is a member of The ESOP Association (TEA) and the National Center for Employee Ownership (NCEO).

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