Mark Your Calendar


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

Oct. 1:

Establish a SIMPLE IRA or safe-harbor 401(k) plan for 2015 (for businesses starting after Oct.1, as soon as feasibly possibly).

Conform plan operations for any additional benefit restrictions that may apply under IRC Section 436 if you sponsor a single-employer defined benefit plan and haven’t received a certified AFTAP from the plan’s enrolled actuary by September 30.

Oct. 15:

File Forms 5500, 5500-SF or 5500-EZ, and 8955-SSA if you filed Form 5558 for a 2½-month extension.

Make deductible contributions for 2014 if you filed a Form 1040, Schedule C and have an extension of your April 15, 2015, filing deadline.

Set up a SEP plan for 2014 if you filed a Form 1040, Schedule C and have an extension of your April 15, 2015, filing deadline.

Make third quarter contributions to 2015 calendar-year defined benefit plans.

Elect (or elect to change) a standing election to use funding balances to offset minimum funding requirements for single-employer defined benefit plans that lost their standing elections because they changed their enrolled actuary.

Oct. 30: Submit applications for opinion and advisory letters for pre-approved defined benefit plans. This applies only to pre-approved defined benefit mass submitter lead and specimen plans, word-for-word identical plans, M&P minor modifier placeholder applications, and defined benefit non-mass submitter plans. It doesn’t apply to individual plan sponsors who might wish to adopt a pre-approved plan document.

Nov. 2: Give a SIMPLE IRA or SIMPLE 401(k) plan notice to eligible employees of their 2016 salary reduction rights and whether the employer required contributions will be matching or nonelective contributions.

Dec. 2: Give 2016 plan-year notice to eligible employees for safe harbor 401(k) plans and plans containing an eligible automatic contribution arrangement.

Dec. 31:

Distribute 2014 401(k) excess contributions and excess aggregate contributions (both adjusted for 2014 income and losses).

Set up a qualified retirement plan for 2015 (you can’t have retroactive elective deferrals).

Distribute 2015 required minimum distributions (you have until April 1, 2016, to pay the first RMD for a participant who turned 70½ in 2015 or for a participant, other than a 5-percent owner, who retired in 2015).

Revoke a single-employer defined benefit plan sponsor’s previous election to use a funding balance to offset minimum required contributions for the 2015 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, 2015, funding balances to avoid or lift benefit restrictions under IRC Section 436 for single-employer defined benefit plans.

Jan. 15, 2016: Make the 2015 fourth quarter contribution for defined benefit plans.

Jan. 31, 2016: Cycle E individually designed plans must amend for recent law changes and may submit the plan for a determination letter.

Feb. 1, 2016:

File Form 945, Annual Return of Withheld Federal Income Tax. If you made timely and complete deposits of 2015 taxes, you may file Form 945 later – see 2016 Form 945 Instructions.

Trustees and custodians must issue Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc., to recipients of 2015 retirement plan distributions.