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of 8821/2848’s

Note:

Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States

This information is covered in IRC 6058, IRC 6039D and Employee Retirement Income Security Act (ERISA) sections 104 and 4065.

Master Trust Investment Accounts (MTIA)

A DFE includes plans that participate in certain trust accounts, and other investment arrangements. Some DFEs must file Form 5500.

Master Trusts that are DFE(s) must file Form 5500.

Master Trusts that are MTIA must file Form 5500.

Common/Collective Trust (CCT), Pooled Separate Accounts (PSA), 103-12 Investment Entities, and group insurance arrangements are not required to file a Form 5500, however may decide to file a Form 5500 as a DFE.

In certifying the U.S. residency of an employee plan, it is necessary to verify that the administrator or sponsor of an employee benefit plan subject to ERISA (Employee Retirement Income Security Act of 1974) has filed an extension or one of the following returns:

Form 5500, Annual Return/Report of Employee Benefit Plan

Form 5500-EZ, Annual Return of A One-Participant (Owners/Partners and Their Spouses) Retirement Plan or A Foreign Plan

Form 5500-SF, Annual Return/Report of Employee Benefit Plan-Short Form

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▸Contents — Internal Revenue Manual Part 21. Customer Account Services

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