2015 SIMPLE IRA Plan FAQs – Contributions

SIMPLE IRA Plan FAQs – Contributions

What types of contributions may be made to a SIMPLE IRA plan?

Each eligible employee may make a salary reduction contribution and the employer must make either a:

  • matching contribution or
  • nonelective contribution.

No other contributions may be made under a SIMPLE IRA plan.

Can contributions made under a SIMPLE IRA plan be made to any type of IRA?

Contributions under a SIMPLE IRA plan may only be made to a SIMPLE IRA, not to any other type of IRA.

Employee contributions

What is a salary reduction contribution?

A salary reduction contribution is an amount an employee elects to have contributed to his or her SIMPLE IRA, rather than paid in cash. Employers must permit their employees to elect to have salary reduction contributions made at an employee-specified level, expressed as a percentage of compensation for the year or as a specific dollar amount. An employer may not place any restrictions on the amount of an employee’s salary reduction contributions, except to comply with the annual limit on salary reduction contributions.

How much may an employee defer under a SIMPLE IRA plan?

An employee may defer up to $12,000 in 2014 and $12,500 in 2015 (subject to cost-of-living adjustments for later years). Employees age 50 or over can make a catch-up contribution of up to $2,500 in 2014 and $3,000 in 2015 (subject to cost-of-living adjustments for later years). The salary reduction contributions under a SIMPLE IRA plan are “elective deferrals” that count toward the overall annual limit on elective deferrals an employee may make to this and other plans permitting elective deferrals.

Employer contributions

How much must I contribute for my employees participating in our SIMPLE IRA plan?

You’re generally required to either:

  1. match each employee’s salary reduction contribution on a dollar-for-dollar basis up to 3% of the employee’s compensation (not limited by the annual compensation limit), or
  2. make nonelective contributions of 2% of the employee’s compensation up to the annual limit of $260,000 for 2014 ($265,000 for 2015, subject to cost-of-living adjustments in later years). If you choose to make nonelective contributions, you must make them for all eligible employees whether or not they make salary reduction contributions.

Can I reduce the 3-percent matching contribution?

You may elect to reduce the 3-percent matching contributions for a calendar year, but only if:

  1. The limit isn’t reduced below 1 percent;
  2. The limit isn’t reduced for more than 2 years out of the 5-year period that ends with (and includes) the year for which the election is effective; and
  3. You notify employees of the reduced limit within a reasonable time before the 60-day election period during which employees can enter into salary reduction agreements.

To determine if the limit was reduced below 3 percent for a year, any year before the first year in which you (or a predecessor employer) maintain a SIMPLE IRA plan will be treated as a year for which the limit was 3 percent. If you choose to make nonelective contributions for a year, that year also will be treated as a year for which the limit was 3 percent.

Can I suspend, reduce or increase the amount of matching contributions to our SIMPLE IRA plan in the middle of the year?

You cannot suspend or modify your employer matching contributions mid-year. You must make the contributions that you promised your employees in the SIMPLE IRA plan notice.

May I make nonelective contributions instead of matching contributions?

As an alternative to making matching contributions under a SIMPLE IRA plan, you may make nonelective contributions equal to 2 percent of each eligible employee’s compensation for the entire calendar year. You must make the nonelective contributions for each eligible employee regardless of whether the employee elects to make salary reduction contributions for the calendar year. You may, but aren’t required to, limit nonelective contributions to eligible employees who have at least $5,000 (or some lower amount selected by the employer) of compensation for the year.

You may substitute the 2-percent nonelective contribution for the matching contribution for a year, only if:

  1. You notify eligible employees that a 2-percent nonelective contribution will be made instead of a matching contribution; and
  2. This notice is provided within a reasonable time before the 60-day election period during which employees can enter into salary reduction agreements.

Do compensation limits apply when calculating the 2-percent nonelective contribution?

For purposes of the 2-percent nonelective contribution, the compensation taken into account must be limited to $260,000 for 2014 ($265,000 for 2015, subject to cost-of-living adjustments in later years).

Do I have to contribute for a participant who isn’t employed on the last day of the year?

Yes, you do. A SIMPLE IRA plan cannot have a last-day-of-the-year employment requirement. If the employee is otherwise eligible, they must share in any SIMPLE IRA contribution. This includes eligible employees who die or quit working before the contribution is made.

If an employee starts or stops salary reduction contributions in the middle of the year, can I make my 3% match based only on the compensation earned during the period they actually contributed? 

No, you must base your SIMPLE IRA plan employer matching contribution on the employee’s entire calendar-year compensation, regardless of when the employee starts or stops contributing during the year. The maximum matching contribution is always 3% of the employees’ compensation for the entire calendar year. Matching contributions may be made on a per-pay-period basis, or by the due date of the employer’s tax return (including extensions).

Example:  Bob’s annual salary is $50,000 and he starts contributing to his employer’s SIMPLE IRA plan on September 1. He contributes $1,536 through December 31. Bob’s employer must match Bob’s contributions up to 3% of Bob’s calendar-year compensation, or $1,500 (3% of $50,000). It doesn’t matter that Bob only contributed to the plan during the last 4 months of the calendar year.

Example: John earns $60,000 a year. He made a salary reduction contribution of $12,000 to his employer’s SIMPLE IRA plan from January 1 to September 30. John’s employer is required to match John’s contribution up to 3% of his entire calendar-year compensation or $1,800 (3% of $60,000), even though John stopped contributing to the plan on September 30.

Example: Joe’s annual salary is $70,000 and he contributed 1% of his compensation, or $700, to his employer’s SIMPLE IRA plan. Joe’s employer must make a matching contribution of $700 because the employer is only required to match the amount Joe actually contributes during the year up to a maximum of 3% of his calendar-year compensation.

Can I contribute to a SIMPLE IRA of a participant over age 70 ½?

Yes, you must. Employees who are age 70 ½ or over may make salary deferral contributions to their SIMPLE IRAs. Employers must continue to make matching or nonelective contributions to employees’ SIMPLE IRAs even after an employee reaches age 70 ½. However, an employee who is age 70 ½ must also begin to take required minimum distributions from the account.

Employees may not be excluded from participating in a SIMPLE IRA plan based solely on their age.

What happens if I don’t make the matching or non-elective contribution to the SIMPLE IRA plan?

A SIMPLE IRA plan must satisfy certain rules to obtain favorable tax benefits. Failure to satisfy these rules, for example, by not making required contributions, can result in the loss of favorable tax benefits for you and the participants. You can correct certain SIMPLE IRA plan failures. For additional information, review our SIMPLE IRA Plan Fix-It Guide and visit Correcting Plan Errors.

Depositing and deducting contributions

When must I deposit the salary reduction contributions?

You must deposit employees’ salary reduction contributions to their SIMPLE IRAs within 30 days after the end of the month in which the amounts would otherwise have been payable to the employees in cash, according to IRS rules (IRC section 408(p)(5)(A)(i)). For self-employed persons with no common-law employees, the latest date for depositing salary reduction contributions for a calendar year is 30 days after the end of the year, or January 30th.

The Department of Labor rule for deposit of the salary reduction contributions may be stricter. They do have a 7 business day safe harbor rule.

When must I make the matching and nonelective contributions?

You must make matching and nonelective contributions to the financial institution maintaining the SIMPLE IRA no later than the due date for filing your business’s income tax return, including extensions, for the taxable year that includes the last day of the calendar year for which you made the contributions. If you extend your tax return, then you have until the end of that extension period to deposit contributions, regardless of when you file the tax return. However, if you did not deposit the contribution timely, you must amend the tax return and pay any tax, interest and penalties that may apply.

How much of the contributions made to employees’ SIMPLE IRAs may I deduct on my business’s tax return?

You may deduct all contributions made to your employees’ SIMPLE IRAs on your tax return.

Can employees deduct the salary reduction contributions they make to the SIMPLE IRA plan on their Form 1040?

No, employee contributions to a SIMPLE IRA plan are not deductible by participants from their income on their Form 1040. Employee salary reduction contributions to a SIMPLE IRA are not included in the “Wages, tips, other compensation” box of Form W-2, Wage and Tax Statement, and are not reported as income on your Form 1040.

If you are a sole proprietor or partner, however, you would deduct your own salary reduction contributions and your own matching or nonelective contributions on Form 1040, line 28.

If my SIMPLE IRA plan fails to meet the SIMPLE IRA plan requirements, are the tax benefits for me and my employees lost?

Generally, tax benefits are lost if the SIMPLE IRA plan fails to satisfy the Internal Revenue Code requirements. However, you may be able to retain the tax benefits if you use one of the IRS correction programs to correct a failure. In general, when correcting a failure under the program, the correction should put employees in the position they would have been had the failure not occurred.

Reporting and notification requirements

What is the SIMPLE IRA employee notification requirement?

Prior to the employees’ 60-day election period (which generally begins on November 2nd prior to each calendar year), you must provide to each eligible employee:

  • Details concerning the employee’s opportunity to make or change a salary reduction;
  • Your decision to make either a matching or nonelective contribution; and
  • A summary description (that the financial institution where the SIMPLE IRAs are maintained usually provides).

See IRS Publication 560 and the Instructions to Form 5305-SIMPLE and Form 5304-SIMPLE for information on the notification requirement.

Why is last year’s SIMPLE IRA contribution that was made this year shown on this year’s Form 5498 instead of last year’s Form 5498?

The IRS requires that contributions to a SIMPLE IRA be reported on the Form 5498 for the year they are actually deposited to the account, regardless of the year for which they’re made.