by Natalie M. Nathanson, Stephen Pavlick and Adrienne Walker Porter
New Internal Revenue Service (IRS) Form 8955-SSA (the Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits) replaces the Schedule SSA of the Form 5500 annual report. Section 6057(a) of the Internal Revenue Code requires plan administrators of retirement plans subject to the vesting standards under the Employee Retirement Income Security Act of 1974 to report information on separated participants with deferred vested benefits that have not commenced. Starting with the 2009 plan year, plan administrators are required to provide information on separated participants with deferred vested benefits on the new IRS Form 8955-SSA. Form 8955-SSA will generally be required to be filed by the last day of the seventh month after the plan year ends, but the IRS extended the general filing deadline for the 2009 and 2010 plan years until the later of January 17, 2012, or the due date that generally applies for filing Form 8955-SSA for the 2010 plan year.
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