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Solo 401k 5500-EZ: Do I include After tax Solo 401k funds transferred to my Roth IRA in calculating the $250k Form 5500-EZ filing requirement?
QUESTION:
In determining if my Solo 401k exceeds the $250k limit such that I need to file a Form 5500-EZ, do I need to include funds in my Roth IRA that were transferred from my Voluntary After-Tax Solo 401k sub-account?
RESPONSE:
No – the value of the plan does not include retirement accounts outside of the solo 401(k).
For example, a 2022 Form 5500-EZ is required if the total asset value (all cash and assets combined of all participants in the plan) of the solo 401k combined with your Defined Benefit Plan (if any) exceeds $250,000 in value as of 12/31/2022.
If a Solo 401k owner made voluntary after-tax contributions to the Solo 401k during 2022 and then transferred the voluntary after-tax Solo 401k funds to a Roth IRA before 12/31/2022 such that the value of the After-tax Solo 401k sub-account as of 12/31/2022 was zero ($0) then those funds will not be included in determining whether the $250,000 threshold has been met.