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Official form guide
Form 14568H: Model VCP Compliance Statement-Schedule 8: Failure to Pay Required Minimum Distributions Timely
IRS Form 14568-H is a Model VCP Compliance Statement - Schedule 8 used to report Failure to Pay Required Minimum Distributions Timely for a plan. It must include the plan name, Applicant’s EIN, and plan number on each page.
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IRS Form 14568H - Model VCP Compliance Statement-Schedule 8: Failure to Pay Required Minimum Distributions Timely
IRS Form 14568-H is a Model VCP Compliance Statement - Schedule 8 used to report Failure to Pay Required Minimum Distributions Timely for a plan. It must include the plan name, Applicant’s EIN, and plan number on each page.
Risk Radar
Scan points- 1Failing to count affected plan participants separately under each year an RMD was missed is a critical error.
- 2Filing without including the plan name, EIN, and plan number on every page.
- 3Using this form if plan benefits commenced in a timely manner at normal retirement age or upon death.
- 4Forgetting to count affected participants separately for each year of RMD failure.
- 5Not detailing how earnings were determined for defined contribution plans in Section II.
Plain English
This form tells the IRS that a retirement plan did not pay out the required minimum distributions (RMDs) on time or paid too little. By filling it out, the plan explains how it plans to fix the missed payments and asks for relief from potential excise taxes.
Submission Date
- Filing date: 2018-06-28 23:00:08
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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What this form is for
- Use this form when a plan failed to pay Required Minimum Distributions (RMD) timely or paid an amount less than required under Section 401(a)(9) of the Internal Revenue Code (IRC).
- Do not use Form 14568-H if plan benefits did not commence in a timely manner, at the plan’s normal retirement age, or upon the participant’s death.
- Check Form 8950 instead when enclosing required items with this submission.
Form selector
Use this form or another form?
Plan fails to pay RMD and is defined contribution
The correction method involves distributing RMD plus earnings calculated from the failure date.
✓ Check Section II for details
Plan fails to pay RMD and is defined benefit
The correction method involves distributing RMD plus an additional payment representing loss of use.
✓ Check Section II for details
Applicant requests relief from IRC Section 4974 excise tax
Relief is requested if at least one affected participant is an owner-employee or a 10% corporate owner.
✓ Check Section III for details
Deadline or filing window
The trigger event is the failure of the plan to pay Required Minimum Distributions (RMD) timely or adequately. The filing must occur for every year that an RMD was not made, counting affected participants individually for each year of failure. Not stated in the official source regarding a specific deadline following the failure.
Checklist
What you need before filling it out
Plan Name / EIN / Plan Number
The plan name, Applicant’s EIN, and plan number · Each page of the submission
Calendar Years Affected
The specific year(s) an RMD failure occurred · Section I (Table)
Total Amount Missed RMD
The total dollar amount of missed Required Minimum Distributions (excluding earnings) · Section I (Table)
Defined Contribution Correction Method
Dividing adjusted account balance by applicable distribution period for each participant/year. · Section II (DC Plan Only)
Defined Benefit Correction Method
Required minimum distributions plus an additional payment based on plan’s written terms for actuarial equivalence. · Section II (DB Plan Only)
IRC 436(d) Restriction Status
Yes/No indicator regarding lump sum restrictions at the time of correction. · Section II (Page 2, DB only)
Before you submit
- 1Ensure the plan name, Applicant’s EIN, and plan number are included on every page.
- 2Verify that the form is used because RMDs were not paid timely or were less than required under Section 401(a)(9).
- 3Count affected participants separately for each year an RMD failure occurred in Section I.
- 4For defined contribution plans, confirm earnings are calculated from the date of failure to the date of distribution.
- 5If a defined benefit plan is subject to IRC Section 436(d) restrictions and answers 'Yes', ensure the corrective distribution amount equals the stated correction. | If 'No' is checked, attach the AFTAP certification.
- 6If requesting relief under IRC Section 4974 (Section III), confirm at least one affected participant meets the owner-employee or 10% corporate ownership criteria.
- 7Enclose specific calculations demonstrating each aspect of the proposed correction method in Section V.
How to file this form
- 1Complete Section I by listing the Calendar Years, Number of Participants Affected, and Total Amount of Missed Required Minimum Distributions.
- 2Detail the Proposed Method of Correction in Section II, ensuring the calculation matches your plan type (DC or DB).
- 3Fill out the remaining sections (II/III/IV) regarding restrictions, relief requests, and procedural changes.
- 4Attach all required enclosures listed in Section V, including sample calculations demonstrating the proposed correction method for each affected participant.
- 5Sign the form before sending it to the Internal Revenue Service.
Known limitations
- 1The plan cannot use this form if plan benefits did not commence in a timely manner at the plan’s normal retirement age or upon the participant’s death.
- 2If the plan does not comply with Section 401(a)(9) of the Internal Revenue Code (IRC) because RMDs were not paid timely or were less than required, affected participants must be counted separately under each year an RMD was missed, not just in the first failure year.
- 3For defined benefit plans, if the plan is subject to any restriction on lump sum payments under IRC Section 436(d) at the time of correction, a copy of the plan’s most current actuarial certification of the Adjusted Funded Target Attainment Percentage (AFTAP) must be included if 'No' is checked for that restriction.
- 4If the Applicant requests relief regarding excise taxes under IRC Section 4974, an explanation must be submitted if at least one affected participant is either an owner-employee or a 10 percent owner of the plan sponsor corporation.
Field map
Compact field-by-field guide
General Info
2 items
Full legal name and taxpayer identification number (SSN or EIN).
Current mailing address.
Details
2 items
Complete all applicable sections of this form according to the official IRS instructions.
Enter the relevant dollar amount if this form involves tax calculation.
Certification
1 items
Read and acknowledge any certifications required by this form.
Signatures
1 items
Sign and date. Unsigned forms cannot be processed.
Almost done reviewing the fields?
Fillable formOpen in Editor->The current edition is Revision 6 (Rev. 6-2018), dated June 2018. The form references the current EPCRS Revenue Procedure for more up-to-date information.
What changed or needs a fresh check
- Edition date — confirm the revision date reads June 2018.
- Catalog Number — confirm the number reads 66153Y on both pages.
- Mailing address — Not stated in the official source (but must be included with submission).
- Signature — Must be signed before sending, and a copy kept by the filer.
Quick Facts
Downloads
After you file
- 1Retain a copy of Form 14568-H for records.
- 2Include specific calculations demonstrating each aspect of the proposed correction method with the submission.
- 3For defined benefit plans, ensure the submitted calculations illustrate the interest rate used to represent the loss of the use of missed RMDs.
- 4For defined contribution plans, confirm the calculations show how earnings were determined and their impact on corrective distributions.
- 5If a written narrative is attached (because this form cannot be used), ensure it provides all necessary information requested by Form 14568-H.
Sources
- SRCForm 14568-H is the Model VCP Compliance Statement - Schedule 8 used for Failure to Pay Required Minimum Distributions Timely. (Instructions p.1)
- SRCThe plan name, Applicant’s EIN, and plan number must be included on each page of Form 14568-H. (Instructions p.1)
- SRCThis form is not applicable if plan benefits did not start at the normal retirement age or upon participant death. (Instructions p.1)
- SRCFor defined contribution plans, RMDs are distributed after adjusting for earnings from failure to distribution date. (Instructions p.1)
- SRCFor defined benefit plans, the correction includes an additional payment representing loss of use, determined by plan terms. (Instructions p.1)
- SRCIf a written narrative is needed because this form cannot be used, it must provide necessary information requested by Form 14568-H. (Instructions p.1)
- SRCFor defined benefit plans, the correction method involves dividing adjusted account balance by applicable distribution period. (Instructions p.1)
- SRCIf a plan is not subject to IRC Section 436(d) restrictions, an AFTAP certification copy must be included if 'No' is checked. (Instructions p.2)
- SRCThe Applicant requests relief from excise taxes under IRC Section 4974 on Form 14568-H. (Instructions p.2)
Common confusion points
How do I count participants if an RMD failure happened in multiple years?
Affected plan participants must be counted separately under each year that the RMD was not made, rather than just listing them once for the first year of failure.
→ Confirm you are counting per year of failure.
What is 'adjusted account balance' for a defined contribution plan?
It means the actual account balance on the applicable valuation date, reduced by the total missed minimum distributions from prior years.
→ Check Section II for the exact definition used in this form.
How is the additional payment calculated for a defined benefit plan?
This payment represents the loss of use of the RMD amounts and is determined according to the plan’s written terms for actuarial equivalence.
→ Verify your calculation matches the stated methodology for "loss of use".
When do I need to attach an AFTAP certification if my plan is defined benefit?
You must include a copy of the most current actuarial certification of the Adjusted Funded Target Attainment Percentage (AFTAP) if you check 'No' under IRC Section 436(d) restrictions.
→ Check the box for restriction status before deciding on the enclosure.
What determines if I need to explain relief from excise taxes?
You must submit an explanation if at least one affected participant is either an owner-employee or, if the plan sponsor is a corporation, a 10 percent owner of that corporation.
→ Review Section III criteria carefully before answering 'Yes' on the tax relief request.
What should I include in my calculations for defined contribution plans?
The calculations must show how earnings were determined and demonstrate their impact on the calculation of the corrective distributions.
→ Ensure your sample calculations cover this specific element.
Workflow map
Related forms and next steps
Before
Current
After
Often used with
⚠ If something goes wrong
- Form 14568-H itself (if you cannot use this form, attach a narrative to it)
Questions about IRS Form 14568H
What is IRS Form 14568H used for?
This form tells the IRS that a retirement plan did not pay out the required minimum distributions (RMDs) on time or paid too little. By filling it out, the plan explains how it plans to fix the missed payments and asks for relief from potential excise taxes.
Who must file IRS Form 14568H?
The filer is the plan sponsor who identifies that their plan failed to comply with Section 401(a)(9) of the Internal Revenue Code (IRC).
What information does IRS Form 14568H require?
Part I provides identification details and lists the failure; Section II describes the proposed correction method for both defined contribution and defined benefit plans. Section III requests relief regarding excise taxes under IRC Section 4974.
When is IRS Form 14568H due?
The form must be filed when an RMD was not paid in a timely manner or was less than required, with affected participants counted separately for each year of failure.
How do I complete IRS Form 14568H?
The filer must first complete the identification details and list of affected participants in Part I. Then, they detail the correction method in Section II (choosing between defined contribution or defined benefit). Finally, relief requests are detailed in Section III before submission.
What happens if IRS Form 14568H is filed incorrectly?
If the plan does not comply with Section 401(a)(9) requirements because RMDs were not paid timely or were insufficient, this form documents that failure to pay.
How do I count participants if an RMD failure happened in multiple years?
Affected plan participants must be counted separately under each year that the RMD was not made, rather than just listing them once for the first year of failure. Confirm you are counting per year of failure.
What is 'adjusted account balance' for a defined contribution plan?
It means the actual account balance on the applicable valuation date, reduced by the total missed minimum distributions from prior years. Check Section II for the exact definition used in this form.
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