QUESTION:
When is the 2025 Form 5500-EZ due to the IRS?
The due date for the 2025 Form 5500-ez is July 31, 2026. The form is typically filed electronically with the DOL/IRS using the EFAST system. Clients of My Solo 401k Financial who timely request this filing are not charged a fee to prepare and to file it. Most other solo 401k plan providers charge additional fees (sotimes in the hundreds of dollars) to prepare it.
Amount and Due Date for Form 5500-EZ QUESTION:
What value must the solo 401k reach before I have to file and when must the Form 500-ez be filed with the IRS?
If your solo 401k plan balance exceeded $250,000 as of December 31, 2025, a Form 5500-EZ is due to the IRS by July 31, 2026.
Determining $250K Value QUESTION:
How is the $250,000 Limit Determined?
- The total plan assets for all participants under the solo 401k plan must be added to determine if the cumulative balance is over $250,00.
- IMPORTANT: If you participate in multiple solo 401k plans, all the plans assets must be aggregated to determine if the $250,000 threshold has been met. If your self-employed business also sponsors a defined benefit plan (DBP) also know as a Cash Balance Plan, the assets of the solo 401k plan and the DBP must be combined to determine if the greater than $250,00 threshold is met by both plans combined; if it does, a separate Form 5500-ez is required to be filed for each plan.
- If you borrowed from the solo 401k plan (i.e., took a solo 401k participant loan), the balance of the loan as of December 31, 2025 is treated as an asset not a liability so it must be included in the calculation to determine if the $250K threshold filing requirement has been met.
Cash and Real Estate QUESTION:
My Solo 401k is invested in real estate as well as cash in a bank account. Do I just list the cash in the bank?
If your Solo 401k plan includes cash and/or traditional investments (stock, mutual funds, money market, etc.) in a bank/brokerage account & alternative investments (e.g. real estate, notes, etc.), you will need to consider the total value of all plan assets as of December 31, 2023.
Promissory Note Investment QUESTION:
We made loans from the solo 401k to a hard money lender, so basically invested the solo 401k in promissory notes. Do the value of these notes get reported on the Form 5500-EZ?
Yes the value of the promissory notes is included in the fair market value (FMV) of the solo 401k plan as of 12/31/2025, and if it results in the solo 401k plan's value exceeding $250,000, a Form 5500-EZ will need to be timely filed by 7/31/2026.
Where are Distributions Reported on Form 500-EZ QUESTION:
I can't tell where to list the required minimum distribution (RMD) from my solo 401k on the 5500ez, can you please tell me?
Currently, the IRS doe not require the reporting of distributions including RMDs from solo 401k on Form 5500-EZ. Solo 401k distributions are reported on Form 1099-R, however.
Solo 401k Participant Loan QUESTION:
Are the solo 401k loans to myself a plan liability? Seems duplicative because I have to report them in Part V
Value of Real Estate and Alternative Investments QUESTION:
How do I determine the value for real estate or other alternative investments?
For alternative investments, you need to make a reasonable determination of the value of the solo 401(k)'s ownership interest in the investment as of December 31, 2025:
- For real estate, you could work with your real estate agent to consider comps in the area;
- For an interest in a partnership, this will not be the amount listed on the K-1 but rather the value of such partnership interest.
Multiple Participants and Account Types QUESTION:
If there are multiple sub-accounts (e.g. pre-tax, Roth, etc.) and/or multiple participant accounts (e.g. accounts for spouses, partners), you will need to consider the total value of all sub-accounts. My wife and I each have a Solo 401k account (under the same plan). Do we include the total value of both accounts? I also have pre-tax and Roth funds. Do I include the total value of all three accounts?
Part III. 6a through 6c QUESTION:
Part III, 6a. I assume we list total assets of both my account as well as my wife’s? No need to separate them?
Correct that you need to list the total figures for the entire solo 401k plan as a whole not just for each participant. Reason being, both spouse are participating in the same Solo 401(k) plan, and Form 5500-EZ captures the information for the entire plan not just each participant.
Information for Plan Administrator QUESTION:
Why is your information not included on the Form 5500-EZ for the Plan Administrator?
Line 7c Rollover of Deceased Spouse’s Pension QUESTION:
Quick question regarding Form 5500-EZ. In Part III, Section 7c. My husband passed away last year and I received his pension distribution from his pension plan and deposited the funds into my solo 401k plan. Do I report that deposit in 7c?
Yes since you are the surviving spouse that would be deemed a direct-rollover and reported on line 7c of Form 5500-EZ provided the pension firm reported it as as direct-rollover. You can confirm by checking with them or if you received a 1099-R with a code "G" in box 7.
Foreign Solo 401k Investments QUESTION:
Are there additional filing requirements for a solo 401K account when assets are owned outside of the USA?
Foreign investments do not trigger the Form 5500-EZ filing requirement unless when the value of the foreign investment(s) is included in the total value of the solo 401k plan causes the plan to exceed $250,000 in total value.
Reason being, a foreign plan is solo 401k plan maintained outside the U.S. primarily for nonresident aliens. A foreign solo 401k plan is required to file an annual For 5500-EZ return if the employer is a domestic employer or a foreign employer that has income from sources in the U.S. and that deducts plan contributions on its U.S. tax return.
Reporting Contributions in 6a Part III QUESTION:
I am getting ready to mail in my 2024 Form 5500-ez which is due by July 31, 2025 to the IRS. I made “voluntary after-tax” contributions for the year “2024” on "1-04-2025" for each participant. $8,500 for one participant and $17,500 for the other. Do I include these amounts in the total plan assets amount in Part 6a?
Since the contributions were made after the 12/31/2024 it does not get reported in 6a because that section is reserved for reporting the value of the solo 401k plan as of the beginning of the year and the end of the year.
Aggregate Plans QUESTION:
My Solo 401(k) is below $250K. However, I have another 401(k) from former employer that may someday push me above $250K if I were to add the balances of the Solo and former employer together. Does the aggregate 401(k) holdings trigger the Form 5500-EZ filing requirement?
Good question. Only if the former employer 401k plan were transferred to the solo 401k plan and if it caused the value of the solo 401k plan to exceed $250,000 would an annul Form 5500-EZ be required. Reason being, the former employer 401k plan is not sponsored by your self-employed business but rather a W-2 employer that you used to work for.
Contributions Deposited in 2022 for 2021 QUESTION:
Do we count 401k contributions deposited in 2025 for plan year 2024 as part of the 2024 assets? As of 12/31/2024, I did not have over $250K. However, I did make a 2024 contribution in January of 2025 that now put me over the $250k threshold.
No, a Form 5500-EZ will not need to be filed by July 31, 2025 if solo contributions made in 2025 for 2024 will result in the value of the solo 401k value going over $250,000.
Reporting Voluntary After-Tax Contributions QUESTION:
I made “after-tax” contributions. Do I record those as employee contributions?
Yes as voluntary after-tax contributions are always deemed employee/salary deferral contributions.
7b Reporting Solo 401k Pretax or Voluntary After-Tax Contributions QUESTION:
For line 7b, do I also enter the after tax contributions that were converted to the Roth solo 401k?
The conversion for pretax solo 401k or voluntary after-tax solo 401k funds are reported on Form 1099-R not Form 5500-ez. You enter Roth Solo 401k and solo 401k voluntary after-tax contributions in 7b. You don't report pretax or voluntary after-tax solo 401k conversions anywhere on Form 5500-ez.
Form 5500-EZ Filed Separately from Personal or Business Tax Return QUESTION:
Just to confirm, The 5500EZ is filed separately and apart from my 1040 correct? My 1040 should have no reference to the 5500EZ?
Correct. The Form 5500-EZ is for reporting activity that transpired under the solo 401k plan for the prior year and it has its own filing deadline separate and apart from your personal or business tax return.
Locate Prior Form 5500-EZ QUESTION:
How do I get a copy of my previously filed Form 5500-EZ?
You can obtain a copy of previously filed Form 5500-EZs by filling out Form 4506, or by calling the IRS at 1-800-908-9946.
SEP IRA Included in Fair Market Value for Form 5500-EZ $250,000 Filing Amount QUESTION:
If in addition to a solo 401k plan, my self-employed business also sponsors a SEP IRA, does the value of the SEP IRA also have to be included with my solo 401k assets to determine if the $250,000 threshold has been met for filing a Form 5500-EZ?
SEP IRAs are subject to IRA tax rules. In determining if a Form 5500-EZ needs be filed for a solo 401k plan, the value of the SEP IRA is not included, only the value of other solo 401k plans as well as the value of other 401(a) qualified retirement plans for the self-employed (e.g. a defined benefit, profit sharing, money purchase plan) are include when applying the $250,000 limit.
Plan Under $250,000 In Value In Year it Was Closed QUESTION:
Is a final Form 5500-ez required if at the time I closed my solo 401k during the year the market value of the plan was under $250,000?
Yes, a final Form 5500-ez has to be filed when a solo 401k plan is closed regardless if the value was under $250,000 in the year it was closed (i.e., all the solo 401k funds were transferred out or distributed).
Reporting Voluntary After-Tax Contributions QUESTION:
Where on Form 5500-EZ are voluntary after-tax solo 401k contributions reported?
Just like Roth solo 401k contributions made during the year are reported on line "7b Participants," voluntary after-tax solo 401k contributions are also reported on line 7b.
Multiple Solo 401k Plans QUESTION:
I just wanted to confirm that I will not have to file a Form 5500-EZ for either of my 2 (two) solo 401k accounts since they each have a balance of under $250,000.
No that is not correct. Both solo 401k balances have to be aggregated to determine if the total value exceeded the $250,000 threshold. If the combined value exceeded $250,000, then the Form 5500-EZ filing requirement applies.
See the following (page 2) from the Form 5500-EZ instructions.
https://www.irs.gov/pub/irs-pdf/i5500ez.pdf
