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Premium Disaster Relief

Premium Disaster Relief

When the Internal Revenue Service provides relief to taxpayers that are unable to meet a filing deadline because of a major disaster (e.g., a hurricane), PBGC also provides relief.  Prior to July 2, 2018, PBGC issued separate Disaster Relief Announcements for each applicable disaster. Each PBGC announcement was numbered with an applicable four-digit code (e.g., 2018-01, 2018-02).

On July 2, 2018, PBGC issued a Federal Register Notice explaining that rather than issuing stand-alone announcements each time IRS grants disaster relief, PBGC was streamlining the process by issuing a one-time announcement regarding the PBGC disaster relief that comes into play each time IRS grants relief in response to a particular disaster (e.g., which types of filings and notices are covered, what the relief entails, how/when to notify PBGC that your plan qualifies for the relief).Thus, PBGC will no longer be issuing stand-alone announcements related to each disaster relief.

Disaster relief code item on 2018 PBGC Comprehensive Premium Filing

Plans eligible for disaster relief with respect to their 2018 comprehensive premium filing (CPF) are required to report a particular four-digit code to identify which disaster affected the plan.  If your plan is eligible for PBGC disaster relief:

  • Related to a stand-alone PBGC disaster relief announcement (i.e., related to IRS relief granted before July 2, 2018), the applicable code is the number of the applicable PBGC announcement.
  • Per the new one-time announcement (i.e., related to IRS relief granted on or after July 1, 2018), the applicable code (to report on the CPF filing) is the last four digits of the IRS News Release identifying code covering the applicable disaster.  For example, if the applicable IRS News Release is “CA‑2018-04”, report 1804.

PBGC has modified My PAA and the xml schema for uploaded filings to make room for the full eight-character IRS News Release identifying code beginning with 2019 Comprehensive Premium Filings.

IRS news releases announcing tax relief for disasters are listed on IRS’ website. Select the applicable news release on the list to see the text of the announcement.

Avoiding unnecessary notices from PBGC

When an expected premium filing is not received timely, PBGC typically sends a “past due filing notice” to the plan administrator.  We appreciate that receiving such notices can be disconcerting in situations where the filer is eligible for disaster relief.  But, until a filing that includes a disaster relief code is received, PBGC doesn’t know that there’s a good reason the filing hasn’t yet been submitted.

If your plan is eligible for disaster relief, you can stop these notices from being sent simply by letting PBGC know that your plan is eligible for disaster relief.  To do so, just send an email to Premiums@pbgc.gov identifying the plan, the disaster, etc. in advance of the normal due date.

Last updated December 10, 2018