Resources

Upcoming Compliance Deadlines

April 1^st   

• Electronic filings of Form 1099-R for 2023 distributions are due to the IRS. (The deadline is March 31, which falls on the weekend in 2024. The IRS provides that dates that fall on a Saturday, Sunday or holiday are delayed until the next business day.)

April 15^th 

• Deadline for corrective distributions of excess deferral amounts under Internal Revenue Code Section 402(g) to participants.
  
  
• Deadline for the first 2024 minimum funding quarterly installment payment for DB plans that had a funding shortfall in 2023—i.e., due 15 days after the last plan-year quarter-end.
  
  
• Employer contributions are due to the plan’s trust for C corporations with a December 31 fiscal year-end in order to take deductions with no corporate tax extension.

April 29^th

• Deadline for sponsors of single and multiemployer DB pension plans to send their annual funding notice to participants, beneficiaries, and labor organizations representing participants. (The notice must be provided no later than 120 days after the close of the plan year, and 2024 is a leap year.)
  
  
• Small plans—i.e., those covering fewer than 100 participants—must provide the notice by the IRS filing due date of the plan’s Form 5500; the notice takes the place of the summary annual report for a DB plan.

April 30^th

• Reconciliation filing and payment for the 2023 comprehensive Pension Benefit Guaranty Corporation premium due to the PBGC for DB plans that filed an earlier estimated variable rate premium in the October 16, 2023, comprehensive filing.

May 15^th

• Deadline for participant-directed DC plans to supply participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses charged to individual plan accounts during first quarter of this year. (Due 45 days after the end of the quarter.)

June 28^th

• Deadline for retirement plans with publicly traded employer securities to file their Form 11-K annual report—i.e., by 180 days after the end of the retirement plan year.

June 30^th

• Deadline for corrective distributions for failed ADP/ACP tests to highly compensated employees (HCEs), to avoid a 10% excise tax on the employer for EACA plans. (June 30 falls on a weekend in 2024. There is an open question as to whether the IRS rules for extending deadlines that fall on a non-business day apply to corrective distribution deadlines.)