In response to a letter sent by SunGard to the IRS, the IRS clarified certain instructions to the Form 8955-SSA. The IRS resolved a conflict between the line 6 instructions to the Form 8955-SSA and its electronic filing system (FIRE) error codes. The issue was whether a preparer inserted on lines 6a and 6b only participants under category A or whether the preparer inserted all participants reported on line 9 regardless of their category (A, B, C or D).
A participant under categories B, C or D has been previously reported on an SSA. Therefore, pursuant to the instructions, lines 6a and 6b only should include category A participants. Despite clear instructions, preparers electronically submitting Forms 8955-SSA received error codes if the number on line 7 (total of lines 6a and 6b) does not match the number of participants reported on line 9, which includes categories A, B, C and D participants.
The IRS responded that a preparer should follow the instructions and only include category A participants in lines 6a and 6b, as applicable. The IRS also indicated that it was modifying the FIRE system so that the proper reporting will not result in an error code when the number of participants on line 9 does not match the number of participants reported on line 7.
This resolves considerable confusion with respect to lines 6a and 6b Form 8955-SSA reporting.