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ARTICLE · 01 DECEMBER 2023

Newly Released 2023 Form 5500s Reflect Significant Changes

Groom Law Group, Chartered
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Groom Law Group, Chartered

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The Department of Labor ("DOL"), Internal Revenue Service ("IRS") and the Pension Benefit Guaranty Corporation ("PBGC") (collectively, "Agencies") recently released the 2023...

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The Department of Labor ("DOL"), Internal Revenue Service ("IRS") and the Pension Benefit Guaranty Corporation ("PBGC") (collectively, "Agencies") recently released the 2023 Form 5500s containing significant reporting changes for the 2023 year. The new Forms and instructions reflect reporting changes that were adopted in a regulatory package issued in February of 2023. See Annual Reporting and Disclosure, Final Rule, 88 Fed. Reg. 11793 (Feb. 24, 2023); Annual Information Returns/Reports, Final Forms Revisions, 88 Fed. Reg. 119984 (Feb. 24, 2023). They represent another step in the steady march by the Agencies to substantially add to the information reported on the Form 5500 and its complexity. With each new round of Form 5500 revisions, it becomes more and more clear that the Agencies view the Form 5500 as a major enforcement and oversight tool.

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