Plan terminated in mid-06, last participant located and paid out 12/08, leaving approximately $3600 in plan to revert to sponsor sometime in 09. Since all plan lianbilities have been satisfied, can the 08 filing be considered a "final", even though there is still money in the trust?

My understanding of "final 5500" is a requirement of zero assets and zero participants. Unless the "money in the trust" exists only because the (for example 12/29/08) check has not yet been cashed by 12/31/08, then you don't have zero assets at EOY. Anyone else have other information?

The rule is if all assets under a plan (including insurance and annuity contracts) have been distributed to the participants or legally transferred to the control of another plan, and when all liabilities for which benefits may be paid under a welfare benefit planhave been satisified, file a final Form 5500.

If a plan has been terminated but all assets have not been distributed, a Form 5500 must be filed for each year the plan has assets.

Does paid out mean on a cash basis only, or can it include on an accrual basis?
If final distribution was accrued by 12/31/08, the net assets of the plan will be zero. So long as the distribution was made on time, no additional 5500 should be required and "Final" can be checked.