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Do I file Form 5500-EZ under $250,000 in a final plan year?

Why the final-year rule can override the usual under-$250,000 Solo 401(k) filing shortcut.

By Yann LephayPublished · Last updated

Summary

Yes, a final Solo 401(k) plan year can require Form 5500-EZ even when assets are under $250,000. The ordinary $250,000 threshold applies to ongoing one-participant plans. When all assets were distributed or transferred and the plan is ending, the sponsor should evaluate a final return marked final.

Final-year trigger is separate from the $250,000 ongoing-plan threshold.

Ongoing planUsually no filing at $250,000 or lessAssuming no final year and no other trigger.
Final yearCan require Form 5500-EZTriggered by full distribution or transfer of all plan assets.
Product laneOriginal on-time packet onlyLate, amended, and notice cases are outside scope.

The question to ask first

Do not start with the year-end balance alone. Ask whether the plan was ongoing at year end or whether all assets were distributed or transferred during the plan year. A final year is a separate filing trigger.

Example

A Solo 401(k) had $82,000 on January 1 and all assets were rolled out by March 15. The year-end balance is $0, but the plan may still need a final Form 5500-EZ for the short final plan year.

What to keep

Keep beginning statements, transfer confirmations, distribution or rollover records, final account statements, plan termination notes, prior-year filed returns, and any extension record. The signer remains responsible for review and filing.

Common questions

Can I skip Form 5500-EZ if the final balance is $0?

No. A $0 final balance can be exactly why the plan is in a final-return lane. The sponsor still checks whether Form 5500-EZ is required for that final plan year.

Does this apply to an ongoing plan below $250,000?

Usually no for a simple ongoing one-participant plan, but the final-year rule is tested separately.

Can Solo 5500 Desk handle a late final return?

No. The product is for simple original on-time packets, not late, amended, or IRS correspondence cases.