What does a CPA file and check?
Defined benefit plans. The deduction for contributions to a defined benefit plan is based on actuarial assumptions and computations. Consequently, an actuary must figure your deduction limit.
Defined benefit plans. Read Internal Revenue Service, Publication 560 in full (opens in a new tab)
The short answer
A defined benefit plan files Form 5500 with a Schedule SB signed by an enrolled actuary, and its minimum contribution and its deduction run on separate deadlines. The deduction lands on a different return for each type of entity, is capped by section 404(o), and may be capped again by section 404(a)(7) when a 401(k) runs beside the plan. A careful CPA says no when profit swings, cash is thin or the cost of covering staff outweighs the owner's tax saving.
What forms does a defined benefit plan file each year?
A defined benefit plan with employees files Form 5500 each year, or the short Form 5500-SF if it qualifies, with Schedule SB signed by an enrolled actuary. A one-participant plan files Form 5500-EZ when the instructions require it. Form 5500 is due by the last day of the 7th calendar month after the plan year ends.
A one-time extension of up to 2½ months is available by filing Form 5558 on or before the normal due date. A plan the PBGC covers also makes its premium filing with the PBGC. A professional service employer’s plan that has never had more than 25 active participants at any time after September 2, 1974 is not covered, and neither is a plan maintained only for substantial owners.
U.S. Department of Labor, 2025 Form 5500 instructions (opens in a new tab)| Penalty | Amount | Source |
|---|---|---|
| IRS, late Form 5500 | $250 a day, up to $150,000, unless the delay had reasonable cause | Internal Revenue Service, Form 5500 Corner (opens in a new tab) |
| Department of Labor, late or incomplete Form 5500 | Up to $2,739 a day, a separate penalty from the IRS penalty | ERISA 502(c)(2); U.S. Department of Labor, 2025 Form 5500 instructions (opens in a new tab) |
| Missing Schedule SB | $1,000 for each failure, unless due to reasonable cause | 26 U.S.C. 6692 (opens in a new tab) |
When is the deposit due versus the deduction?
Two dates apply. The minimum required contribution for a calendar 2026 plan year is due September 15, 2027, eight and a half months after the plan year ends, under section 430(j)(1) of the tax code. The tax deduction is allowed if the business pays by its return due date, including extensions, under section 404(a)(6).
For a calendar-year S corporation or partnership on extension, both dates fall on September 15, 2027. For a sole proprietor or a C corporation on extension, the deduction date is October 15, 2027, after the funding date. A late minimum contribution draws an excise tax of 10 percent under section 4971, and 100 percent if the amount stays unpaid, even when the deduction itself is still on time.
26 U.S.C. 430(j)(1) (opens in a new tab)26 U.S.C. 404(a)(6) (opens in a new tab)26 U.S.C. 6072(b) and 6081(a); 26 U.S.C. 6072(a) and 6081(a) (opens in a new tab)Where does the deduction sit on each entity's return?
A C corporation deducts the contribution on Form 1120, and an S corporation deducts it on Form 1120-S. A partnership reports it on Form 1065 and passes each partner’s own contribution through on Schedule K-1, box 13, code R, for the partner to deduct personally. A sole proprietor deducts the owner’s own contribution as an adjustment to income.
| Entity | Where the deduction is taken | Plan compensation | Source |
|---|---|---|---|
| C corporation | The corporate return, Form 1120 | W-2 wages | IRS Publication 560 (opens in a new tab) |
| S corporation | Form 1120-S | The owner’s W-2 wages, which must be reasonable for the work done | IRS Publication 560 (opens in a new tab) |
| Partnership | Form 1065; each partner’s own contribution passes through on Schedule K-1, box 13, code R | Earned income, figured after the plan deduction itself | Form 1065 instructions; 26 U.S.C. 401(c)(2) (opens in a new tab) |
| Sole proprietor | The owner’s own contribution as an adjustment to income; the employee share as a business expense | Earned income, figured after the plan deduction itself | 26 U.S.C. 62(a)(6) and 401(c)(2) (opens in a new tab) |
Earned income figured after the plan deduction makes the calculation circular, and the actuary solves it. Check the line numbers against the current year’s Publication 560 and form instructions before you file.
What is the section 404(o) deduction ceiling?
For a single-employer defined benefit plan, the deductible amount is the greater of the plan’s funding target plus its target normal cost plus a cushion, less plan assets, or the minimum required contribution under section 430. The cushion is why the maximum deductible amount can sit far above the minimum. An actuary figures both.
A contribution above the deductible amount draws an excise tax of 10 percent of the nondeductible contributions, owed by the employer as of the close of its tax year.
26 U.S.C. 404(o)(1); 26 U.S.C. 4972(a) (opens in a new tab)How do I figure the combined deduction with a 401(k)?
When a defined benefit plan runs beside a 401(k) with overlapping participants, the combined deduction is capped at the greater of 25 percent of covered pay or the defined benefit minimum. Employer 401(k) contributions of up to 6 percent of pay are left out of the cap, and employee deferrals are never counted.
Above 6 percent of pay, only the excess counts. A 412(e)(3) plan counts as a defined benefit plan for this rule. The cap does not apply at all to a defined benefit plan the PBGC covers, but a professional service employer’s plan that has never had more than 25 active participants at any time after September 2, 1974 is not covered, and neither is a plan maintained only for substantial owners.
In applying this paragraph, any single-employer plan covered under section 4021 of the Employee Retirement Income Security Act of 1974 shall not be taken into account.
Only a plan the PBGC actually covers is left out. Read 26 U.S.C. 404(a)(7)(C)(iv) in full (opens in a new tab)
Which coverage and nondiscrimination tests apply?
Several sets of rules decide who the plan must cover and what each person must receive: minimum participation under section 401(a)(26), coverage under section 410(b), nondiscrimination under section 401(a)(4), usually met by testing the plans together with the gateway in the regulations, and the top-heavy rules in section 416. The table gives each test’s own figures.
| Test | What it requires | Source |
|---|---|---|
| Minimum participation | On each day of the plan year, the plan benefits at least the lesser of 50 employees, or the greater of 40 percent of all employees or 2 employees | 26 U.S.C. 401(a)(26) (opens in a new tab) |
| Coverage | The plan benefits at least 70 percent of employees who are not highly compensated, or passes the ratio or average benefit test | 26 U.S.C. 410(b)(1)(A) (opens in a new tab) |
| The gateway, when plans are tested together | Each employee who is not highly compensated gets at least one third of the highest rate among highly compensated employees, or 5 percent of pay if less, while that rate is 25 percent or under; 7½ percent of pay is treated as passing | 26 CFR 1.401(a)(4)-9(b)(2)(v)(D)(1); 26 CFR 1.401(a)(4)-9(b)(2)(v)(D)(2) (opens in a new tab) |
| Top-heavy | Top-heavy when key employees hold more than 60 percent of accrued benefits; employees who are not key then receive at least the lesser of 2 percent times years of service or 20 percent of average pay | 26 U.S.C. 416(g)(1)(A)(i); 26 U.S.C. 416(c)(1)(B) (opens in a new tab) |
| Vesting, cash balance plan | Fully vested after no more than 3 years of service | 26 U.S.C. 411(a)(13)(B) (opens in a new tab) |
No law sets a share of the contribution that staff will receive. The actuary’s tests on the client’s census decide the staff share.
What does the enrolled actuary certify?
An enrolled actuary, licensed by the federal Joint Board for the Enrollment of Actuaries, values the plan each year, certifies the minimum and maximum contribution, and signs Schedule SB of the plan’s Form 5500. The deduction limit for a defined benefit plan must be figured by an actuary, and the IRS says so in Publication 560.
Schedule SB reports the funding target, the target normal cost, the minimum required contribution and the funding target attainment percentage. Ask for the signing actuary’s name and enrollment number before you rely on any figure the actuary produces.
Internal Revenue Service, Defined benefit plan page (opens in a new tab)Internal Revenue Service, Publication 560 (opens in a new tab)What documents should I ask for before the client signs?
Ask for the census the proposal used, the illustration with every assumption stated, the proposed plan document and adoption agreement, the trust or custodial agreement, the plan’s yearly cost in writing, a sample Schedule SB, and the name and enrollment number of the actuary who will sign. Read the plan document before the client signs it.
In the plan document, look for the vesting schedule, how the interest credit is set, whether in-service distributions or loans are allowed, and what happens to any surplus when the plan ends. Ask who files each form, who signs each one, and whether the client keeps its own custodian.
When do professionals decline to recommend one?
A careful CPA declines when profit swings from year to year, when cash is thin, when the cost of covering staff outweighs the owner’s tax saving, when a sale or wind-down is likely soon, or when the owner wants a single year’s deduction or believes the plan erases tax rather than deferring it.
A defined benefit plan defers tax. Contributions are deducted now and taxed as ordinary income when paid out, and a distribution before age 59½ carries a 10 percent additional tax unless an exception applies.
26 U.S.C. 72(t)(1) (opens in a new tab)What should a client hear about the risks?
The IRS lists the defined benefit plan as the most costly and the most administratively complex type of plan. The contribution is mandatory each year within the actuary’s range, and an unpaid minimum is taxed at 10 percent, then 100 percent. The employer bears the investment risk, so a shortfall raises future contributions.
Benefits do not depend on how the plan’s investments do. The money is locked until age 59½, separation or plan termination, with a 10 percent additional tax on early distributions. Staff must be covered and credited under federal tests. Fees for the actuary, the administrator and the filings are due every year.
Internal Revenue Service, Defined benefit plan page; 26 U.S.C. 4971(a)(1); 26 U.S.C. 72(t)(1) (opens in a new tab)How do I explain the funding commitment to a client with uneven income?
Show the client the minimum required contribution in a weak year, not the maximum in a good one. The minimum is mandatory every year the plan exists, and an unpaid minimum is taxed at 10 percent, then 100 percent. If the client cannot carry the minimum in the weak case, a plan with optional contributions fits better.
The law gives a bad year some room. A funding shortfall is paid off in level installments over 15 plan years. A waiver of the minimum needs a temporary substantial business hardship, is granted for no more than 3 of any 15 consecutive plan years, and is repaid over 5 plan years. An amendment that cuts future benefits needs written notice at least 45 days ahead, or 15 days for a plan with fewer than 100 participants.
26 U.S.C. 430(c)(8); 26 U.S.C. 412(c)(1)(A); 26 U.S.C. 430(e)(2)(A) (opens in a new tab)ERISA 204(h); 26 CFR 54.4980F-1, Q&A-9 (opens in a new tab)Checked on October 15, 2026.