Can the alternative reporting option for eligible indirect compensation be used to report compensation paid or received in separately managed investment accounts of a single plan?
Yes. The Schedule C instructions state that eligible indirect compensation includes fees or expense reimbursement payments charged to investment funds and reflected in the value of the plans investment or return on investment. The instructions do not further define the term investment fund for this purpose. Investment funds would include mutual funds, bank common and collective trusts, and insurance company pooled separate accounts. In the Departments view, the term would also include separately managed investment accounts that contain assets of an individual plan. Thus, so long as the other conditions for eligible indirect compensation are met, the Schedule C alternative reporting option can be used for indirect compensation received in connection with separately managed investment accounts of employee benefit plans.
Related Questions
- Can the alternative reporting option for eligible indirect compensation be used to report compensation paid or received in separately managed investment accounts of a single plan?
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