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Mark Your Calendar

Here are some important deadlines in the upcoming months. Most of the dates are for calendar-year retirement plans; non-calendar-year plans must adjust some of these dates.

Dec. 31, 2014:

  • Distribute 2013 401(k) excess contributions and excess aggregate contributions (both adjusted for 2013 income and losses).
  • Establish a qualified retirement plan for 2014 (you can’t make retroactive elective deferrals.)
  • Distribute 2014 required minimum distributions (you have until April 1, 2015, to pay the first RMD for a participant who turned 70 ½ in 2014, or for a participant other than a 5% owner, who retired in 2014.)
  • Revoke a single-employer defined benefit plan sponsor’s previous election to use a funding balance to offset minimum required contributions for the 2014 plan year, to the extent the election exceeded the full minimum required contribution for the year. This deadline only applies to plans with valuation dates as of the first day of the plan year.
  • Elect to reduce Jan. 1, 2014, funding balances to avoid or lift benefit restrictions under IRC Sect. 436 for single-employer defined benefit plans.
  • Recertify a single-employer defined benefit plan’s 2014 AFTAP if it had previously been certified using MAP-21 rates on or before Sept. 30, 2014, and the use of Highway and Transportation Funding Act (HATFA) rates causes a material change (deadline applies if changes in IRC Sect. 436 restrictions are applied prospectively) – see Notice 2014-53.
  • Make elections under HATFA:
    • Revoke a deemed election to defer using HATFA rates for a single-employer defined benefit plan to 2014 by either providing written notice or filing an amended Form 5500, 5500-SF or 5500-EZ for the 2013 plan year.
    • Restore any single-employer defined benefit plan’s funding balances if a reduction made before applying HATFA rates is no longer necessary (if the original election was made on or before Sept. 30, 2014).
    • Add excess 2013 contributions made on or before Sept. 30, 2014, to a single-employer defined benefit plan to the plan’s 2014 funding balances (only if HATFA rates apply for 2013).
    • Redesignate any single-employer defined benefit plan contributions no longer needed for 2013 as 2014 contributions (only if HATFA rates apply for 2013 and the original contribution was made between Jan. 1, 2014 and Sept. 30, 2014).
  • Make one-time elections under the Cooperative and Small Employer Charity Pension Flexibility Act of 2014 (the CSEC Act):
    • Elect not to treat a plan as a CSEC plan, meaning that it would not be subject to the special rules for CSEC plans1.
    • Elect not to treat a plan as an eligible charity plan and comply with PPA’06 rules retroactively for all years beginning with the 2008 plan year (election due to the IRS by December 31, 2014, regardless of the plan’s plan year).

Jan. 15, 2015: Make the 2014 fourth quarter contribution for defined benefit plans.

Feb. 2:

  • Cycle D individually designed plans must amend for recent law changes and may submit the plan for a determination letter.
  • File Form 945, Annual Return of Withheld Federal Income Tax. If you made complete deposits of 2014 taxes, you may file Form 945 by Feb. 10, 2015.
  • Trustees and custodians must issue Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc., to recipients of 2014 retirement plan distributions.

March 2: File paper Form 1099-R and Form 1096, Annual Summary and Transmittal of U.S. Information Returns, for 2014 with IRS. If you file Form 1099-R electronically, the due date is March 31, 2015.

March 15:

  • Apply for waiver of 2014 minimum funding standard for single-employer defined benefit plans if the sponsor won’t be able to make the required contribution and will meet the conditions to qualify for a funding waiver.
  • Distribute 2014 ADP/ACP excess amounts, with earnings, to highly compensated employees to avoid 10% excise tax (June 30, for certain eligible automatic contribution arrangements).
  • Make 2014 corporate employer contributions to be eligible to take a tax deduction for 2014 (if no extension was filed for tax return).
  • Set up SEP plan for 2014 if your business is a corporation (Sept. 15, 2015, if you file for an extension for your Form 1120).

March 16:

File Form 1042-S, 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, with the IRS to report retirement plan distributions and income tax withheld from distributions to nonresident aliens.

March 31:

Obtain certified AFTAP from the enrolled actuary for a defined benefit plan, to avoid the reduction in presumed AFTAP (and potential additional benefit restrictions under IRC Sect. 436) otherwise effective April 1.


1 This election is only available to approximately 30-35 plans. CSEC plans are defined in IRC Sect. 414(y), and are generally (1) plans maintained by more than one employer, at least 85% of which are cooperative organizations and related entities, or (2) plans maintained by more than one employer (taking into account the controlled group rules in IRC Sect. 414(b) or (c)), all of which are described in IRC Sect. 501(c)(3).

Page Last Reviewed or Updated: 18-Dec-2014