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Official form guide
IRS Form 8905 is Certification of Intent to Adopt a Pre-approved Plan, used by an adopter of a plan to request conversion from the 5-year to the 6-year remedial amendment cycle under Part IV of Rev. Proc. 2007-44. This form must be completed before the end of the employer’s applicable five-year remedial amendment cycle.
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IRS Form 8905 is Certification of Intent to Adopt a Pre-approved Plan, used by an adopter of a plan to request conversion from the 5-year to the 6-year remedial amendment cycle under Part IV of Rev. Proc. 2007-44. This form must be completed before the end of the employer’s applicable five-year remedial amendment cycle.
Plain English
This form tells the IRS that a company intends to adopt a pre-approved retirement plan. By filing Form 8905, the company requests that its standard 5-year deadline for making amendments be extended to 6 years. The employer and the plan sponsor must sign this document to confirm their intent.
Submission Date
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Adopting Master/Prototype plan
Needed to apply for determination for adopters of M&P or Volume Submitter Plans.
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Terminating a plan
Needed when applying for determination specifically for a Terminating Plan.
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No specific application form is used
If no Form 5300, 5307, or 5310 filing is made, the employer must keep the original certification in their records and should not file Form 8905 with the IRS.
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The filing deadline is before the end of the employer’s 5-year remedial amendment cycle, as determined under Part III of Revenue Procedure 2007-44. The form must be completed by attaching it to an application like Form 5300 or Form 5310.
Checklist
Part III Certifications
Both parties must sign and date before the end of the employer’s applicable five-year remedial amendment cycle as determined under Part III of Rev. Proc. 2007-44 · Form 8905, Page 1
Line 1b (EIN)
The 9-digit EIN assigned to the plan sponsor/employer · Form 8905, Part I
Line 2c (Plan Name)
The name of the M&P plan or volume submitter specimen plan the employer intends to adopt (e.g., Volume Submitter Profit Sharing Plan) · Form 8905, Part II
Part I Line 1e (Plan Type)
Enter '1' for Defined Contribution Plan (DCP) or '2' for Defined Benefit Plan (DBP) · Form 8905, Part I
Line 4 Date
The date by which the opinion or advisory letter application was or must be submitted as determined under Part IV of Rev. Proc. 2007-44 · Form 8905, Page 1
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Entity Info
1 items
Name and taxpayer ID of the entity claiming the credit.
Credit Info
1 items
Type of credit or incentive being claimed.
Calculation
2 items
The base amount used to calculate the credit.
Calculated credit amount after applying formulas and limitations.
Certification
1 items
Detailed breakdown supporting the credit calculation.
Signatures
1 items
Sign and date the form.
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Fillable formOpen in Editor->The current edition is 1-2012. The source does not specify a dedicated 'latest information' page, but the form itself indicates it is from January 2012.
Quick Facts
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What if we don't file Form 5300, 5307, or 5310?
The form states that if no application filing occurs, the employer should keep the original certification in their records and should not file Form 8905 with the IRS.
→ Confirm you are either attaching it to an application OR keeping a copy for your files.
Do both parties need to sign Part III?
Yes; the certification must be signed and dated by both the employer and the pre-approved plan sponsor or practitioner.
→ Verify signatures and dates appear on Part III before mailing.
Can we use a digital signature for everyone?
The employer must manually sign the form, but the M&P sponsor and volume submitter practitioner may use a stamped, scanned, or electronic signature.
→ Check who signs what: Employer = Manual; Practitioner/Sponsor = Stamped/Scanned/Electronic.
What is the difference between 'DCP' and 'DBP'?
DCP stands for defined contribution plan, which requires entering '1' on Line 1e. DBP stands for defined benefit plan, which requires entering '2' on Line 1e.
→ Check Line 1e to ensure you entered '1' or '2' correctly based on your plan type.
Where does the date on Line 4 come from?
Line 4 requires the date by which the opinion or advisory letter application for the M&P plan was or must be submitted, as determined under Part IV of Rev. Proc. 2007-44.
→ Ensure this date matches the requirement set forth in the instructions/part IV.
Do we use our EIN or the trust's EIN on Line 1b?
The employer must enter the 9-digit EIN assigned to the plan sponsor/employer, not a social security number or the EIN of the trust.
→ Double-check that the EIN in Line 1b belongs specifically to the *plan sponsor/employer*.
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⚠ If something goes wrong
This form tells the IRS that a company intends to adopt a pre-approved retirement plan. By filing Form 8905, the company requests that its standard 5-year deadline for making amendments be extended to 6 years. The employer and the plan sponsor must sign this document to confirm their intent.
An adopter of an individually designed plan or pre-approved plan (if not otherwise entitled to the 6-year remedial amendment cycle) files Form 8905 when necessary to request that their 5-year remedial amendment cycle be converted to the 6-year remedial amendment cycle.
Part I collects Plan Sponsor Information, including the employer's name and EIN. Part II details the M&P sponsor or volume submitter practitioner, while Part III contains certifications signed by both parties.
Form 8905 must be completed before the end of the employer’s 5-year remedial amendment cycle as determined under Part III of Revenue Procedure 2007-44.
The completed Form 8905 is filed by attaching it to one of three applications: Form 5300, Form 5307, or Form 5310. The employer must not file the form with the IRS alone if no application filing occurs.
First, complete Part I with the employer's details and Part II with the M&P sponsor/practitioner information. Next, both parties must sign and date Part III before the end of the applicable 5-year remedial amendment cycle. The employer must manually sign this certification.
If an employer does not file Form 8905 with one of the required applications (Form 5300, 5307, or 5310), they should keep the original certification in their records and should not file it with the IRS.
The form states that if no application filing occurs, the employer should keep the original certification in their records and should not file Form 8905 with the IRS. Confirm you are either attaching it to an application OR keeping a copy for your files.
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