UPDATE: IRS Extends Form 5500 Filing Deadline for Off-Calendar-Year Plans


On April 9, 2020, the IRS issued Notice 2020-23 to extend numerous tax code deadlines for employee benefit plan sponsors and other taxpayers. The notice provides that, if certain specified actions are required to take place between April 1, 2020, and July 15, 2020, the new deadline will be automatically extended to July 15, 2020.

The notice included Form 5500 filings as one of the many actions that can be delayed. For plans with a July–June plan year, the Form 5500 filing deadline was April 15 if the plan had requested an extension before January 31. For those plans, the new filing deadline will be July 15, 2020.

Please note, however, that organizations required to file a Form 5500 for a calendar-year plan – those administered using a January plan year – are still subject to the usual July 31, 2020, deadline.

On May 28, the IRS issued Notice 2020-35, which expanded the July 15 deadline relief to additional time-sensitive acts. These include applying for a funding waiver under Section 412(c) for a single-employer defined benefit plan and adopting certain corrective amendments, as well as Form 5300 used to file for an IRS determination letter, and Form 5330 used to self-report a prohibited transaction and pay the required excise tax. (Other actions included in Notice 2020-35 have deadlines separate from July 15.)

If you have any questions, please contact your local Mutual of America representative.



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