A plan with two active participants is implemented on 1/1/2004.
The plan is not considered a one-participant plan and thus is not eligible to file a 5500EZ, so must file a 5500.
In the first plan year the corporation has no profits and pays no compensation and thus no benefits accrue and there is no funding requirement for 2004.
However, one of the participant's rolls $50,000 into the plan during 2004.
The client just now provides us this information regarding a rollover and never filed a 5500 for 2004.

Any suggestions on a strategy for this situation?

Thanks.

Do the 5500 ASAP and file it under the DOL DFVC program. Max penalty is $750. Don't think there are any other good options.

I agree, the "100K" rule only applies to EZ filers. Did you check to see if a PBGC filing is also necessary?