IRS Form 15417-E – In the world of retirement planning, ensuring compliance with IRS regulations is crucial for avoiding penalties and maintaining tax-advantaged status. One key tool for this is IRS Form 15417-E, specifically the 403(b) Plan Required Minimum Distributions Worksheet 9A, which focuses on the determination of 403(b) status. This worksheet helps plan administrators and participants verify that a 403(b) plan meets the required minimum distribution (RMD) rules under section 401(a)(9) of the Internal Revenue Code. Released in April 2023, this form is essential for non-profit employees, educators, and others utilizing 403(b) plans to manage their retirement savings effectively.
Whether you’re a plan sponsor, financial advisor, or individual participant, understanding this worksheet can streamline compliance and prevent costly errors. In this SEO-optimized article, we’ll break down the form’s purpose, structure, and usage, drawing from official IRS sources to provide accurate, up-to-date information as of 2026.
What is a 403(b) Plan?
A 403(b) plan, also known as a tax-sheltered annuity (TSA) plan, is a retirement savings vehicle designed for employees of public schools, certain tax-exempt organizations, and ministers. Similar to a 401(k) but tailored for non-profits, it allows pre-tax contributions, employer matching in some cases, and tax-deferred growth. Contributions are limited annually, and distributions are generally taxed as ordinary income.
These plans are governed by IRC section 403(b) and must adhere to various IRS rules, including those for required minimum distributions. Failure to comply can result in plan disqualification or excise taxes on undistributed amounts.
Required Minimum Distributions (RMDs) in 403(b) Plans
Required minimum distributions are mandatory withdrawals from retirement accounts starting at a certain age to ensure that savings are not deferred indefinitely for tax purposes. For 403(b) plans, RMD rules apply similarly to traditional IRAs and other qualified plans. Generally, account holders must begin taking RMDs by April 1 of the year following the year they turn 73 (as updated under the SECURE 2.0 Act).
The amount is calculated based on the account balance and life expectancy factors from IRS tables. For 403(b) plans, each investment arrangement (like annuities or custodial accounts) is treated individually for RMD purposes, unless aggregated under specific rules. Non-compliance can lead to a 25% excise tax on the shortfall, reducible to 10% if corrected timely.
Worksheet 9A specifically addresses how a 403(b) plan incorporates these RMD requirements, ensuring the plan document aligns with IRC section 401(a)(9) and related regulations.
Overview of IRS Form 15417-E Worksheet 9A
Form 15417-E is a specialized worksheet titled “403(b) Plan Required Minimum Distributions Worksheet 9A – Determination of 403(b) Status.” It’s part of a series of IRS worksheets (e.g., referenced in Publications like 7004) used during plan reviews or audits to confirm compliance. The form, cataloged as Number 94033Z, emphasizes that all 403(b) plans must include provisions for minimum distributions under 401(a)(9).
The worksheet is divided into three main sections, each representing an acceptable method for incorporating RMD rules: Incorporation by Reference, Alternative 401(a)(9) Language, or Governmental Plans. Users must complete all relevant items, with “Yes” answers indicating compliance and “No” answers requiring explanations. The form notes that technical principles may evolve with future IRS regulations.
Section I: Incorporation by Reference
This is the most straightforward method for many plans. It checks if the plan document references compliance with 401(a)(9) regulations without restating them fully.
- Question a: Does the plan state that it will comply with minimum distribution requirements per the terms of each investment arrangement, unless otherwise permitted by law or IRS rules?
- Question b: Does it treat each investment as an IRA for distribution purposes under Treas. Reg. § 1.408-8, with exceptions in § 1.403(b)-6(e)?
A “Yes” to both confirms proper incorporation. If “No,” explain issues like missing references.
Section II: Alternative 401(a)(9) Language
If not using incorporation by reference, plans can include direct language mirroring 401(a)(9) rules. This section has one key question:
- Question a: Does the plan provide compliant language under 401(a)(9), regulations §§ 1.401(a)(9)-1 through -9, and § 1.408-8, except as in § 1.403(b)-6(e)? Cross-reference Worksheet 9 in Publication 7004 for details.
“Yes” means the custom language suffices; “No” requires fixes.
Section III: Governmental Plans
Exclusive to governmental 403(b) plans, this allows a “reasonable and good faith interpretation” of 401(a)(9) if not using Section I.
- Question a: Does the plan offer such an interpretation?
Compliance here is more flexible but still demands documentation for any “No” responses.
How to Use Worksheet 9A for Determining 403(b) Status
To use the worksheet:
- Enter the plan’s name at the top.
- Select the applicable section based on your plan’s structure (e.g., start with Section I for most plans).
- Answer each question with “Yes,” “No,” or “N/A,” citing plan references.
- Explain any “No” answers in the provided space.
- Consult IRS guidelines if needed, as the form may be updated.
This process helps determine if the plan maintains its 403(b) status for RMDs. For related tools, see IRS RMD worksheets for IRAs, which can aid in calculations.
Note: This is not tax advice; consult a professional for personalized guidance.
The Importance of Compliance with IRS Form 15417-E
Adhering to Worksheet 9A ensures your 403(b) plan avoids IRS scrutiny during audits or determination letter applications. Non-compliance could jeopardize tax-deferred status, leading to back taxes and penalties. With recent changes like the SECURE Act adjustments to RMD ages, staying current is vital.
For church-related plans, check related Form 15417-I for 403(b)(9) retirement income accounts.
Frequently Asked Questions (FAQs)
What if my plan is a governmental 403(b)?
Use Section III for a good faith interpretation, but ensure it aligns with 401(a)(9).
Where can I download IRS Form 15417-E?
Access it directly from the IRS website: https://www.irs.gov/pub/irs-pdf/f15417e.pdf.
Do RMD rules apply to Roth 403(b) accounts?
No, Roth accounts are exempt from RMDs during the owner’s lifetime.
How do I calculate my RMD?
Use IRS life expectancy tables and account balances as of December 31 of the prior year.
By mastering IRS Form 15417-E and Worksheet 9A, you can better navigate 403(b) plan requirements, ensuring a secure retirement. For the latest updates, always refer to official IRS resources.