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Thank you for clarifying.

for FuturePlan, by Ascensus (Remote / PA)View the full text of this job opportunity

for Ascensus (Remote)View the full text of this job opportunity

I've been presented with this situation: Two spouses own two S-corps - MS owned by J 51% and her husband O 49% OC owned 100% by O It's a controlled group because O owns part of MS. Each business has only one other employee, an NHCE. OC has a 401k plan (I don't have any other details yet). Of course, J wants a 401k plan to cover MS... and only MS. I want to say that as long as the populations are stable, then this is OK. No matter what feature I put into the MS plan, I'll either have: 1 HCE benefitting, 1 HCE nonbenefitting, 1 NHCE benefitting, and 1 NHCE nonbenefitting = 1/2 / 1/2= 100% or 2 HCE benefitting, 2 NHCE benefitting = 2/2 / 2/2= 100% This seems... simplistic? Like I'm missing something? What trap am I unwittingly walking into (other than the one where one of the NHCEs leaves and the testing fails and it's a disaster). Thanks!

If participant died in 2020 and estate is beneficiary (subject to 5-year rule), CARES act said 2020 is ignored for purposes of 5-year rule. Is distribution due in 2026, or was it due in 2025? Recordkeeper is arguing that we create a fiction that participant died in 2021, such that distribution is due in 2026. I don't think that's what CARES Act said but it would be a good result if everyone here thinks recordkeeper is right!

From the instructions, the years would be 2022, 2023 and 2024 since the enrollment expires 9/2025. Calendar years are used.

for BPAS (Utica NY)View the full text of this job opportunity

Yes

Good morning. Husband is due an RMD in 2026 because he had reached RMD age. Since he died before receiving his RMD for 2026, it is required to be distributed to his beneficiary (his wife as the sole spouse beneficiary) on or before December 31, 2026. Wife does not have the option to waive Husband's 2026 RMD. Wife will be required to begin receiving RMDs based on her DOB in 2027 (wife will need to elect ULT treatment if plan has not been amended to use the ULT as the default under the plan). I recommend checking language in the plan document.

This is a profit sharing plan with spouse owners only. Both are subject to the RMD. Husband died January 2026. Wife is the primary beneficiary. The Plan requires the RMD in year of death be based on the deceased date of birth and the beneficiary's DOB in the following years. Does the wife have the option of waiving the 2026 RMD without penalty? If she is eligible to waive, will she be subject to both 2026 and 2027 in 2027? Due to the non-liquid nature of plan investments, I do not believe she will be able to roll the husbands benefit to an IRA at this time. Thank for your help.

for Cetera Retirement Plan Specialists (Coppell TX / West Des Moines IA / Hybrid)View the full text of this job opportunity

Brian - Thank you!! This is so helpful! And glad to see I'm on track here and can continue to contribute the family max for a few years yet. Very much appreciate your time!

Before IRAs’ custodial-account agreements next are amended (by December 31, 2027), those accounts will have been operated for about eight years with at least some in-operation provisions different than the ostensible written provisions. How does an individual learn which provisions are real, and which are displaced by Internal Revenue Code and other law changes? Remember, many, perhaps most, of an IRA’s tax-sensitive provisions call for an individual to administer her account. Often, a custodian is protected in following the account holder’s instructions. Why does the IRS not allow an agreement to state provisions by referring to the Internal Revenue Code?

I have heard of consequences from not filing a Final 5500. The two partners rolled their plan accounts to IRAs and thought that was that. Five or so years later, the IRS said your money purchase plan is still on-going. Where is your latest restatement and 5500 filing? I don't know what it cost to untangle the mess.

Many practitioners are overly generous. A fee should include not only the work but also something for availability. Whether that’s through an explicit fee for availability or, when there is work, a task-based fee or a time-based fee priced with a margin for availability might turn on one’s profession’s rules.

In 2023, I received the renewal due by January 31st email and submitted my application in January as instructed. They came back with a reply that I submitted too early and would need to resubmit after April 1, and pay again too. So don't do it early!

As a former TPA I will tell you these are generally not great clients. I dont mean in the sense that they are jerks or that they don't pay their bills. I mean they are so "unusual" from an operational perspective that only a partner can assist and answer their questions. There is no detailed work ti be done, so not much that a staff person can do. So if you bring on one of those clients, it's basically 100% partner time which starts to raise the quesiton of "can you charge enough money." I used to tell clients, "it's not worth it for you to pay me what I need to get paid to do this work for you, but I cant do it for any less. If you want me to be available to you when you call, I need a decent fee." I would review the plans all the time throughout the year for, amendments needed, invoicing, collections, you name it. Just having a plan on the books takes time even if I'm not doing any work. I used to charge $1,250 a year and I still think it wasn't enough sometimes.

For your questions, is your assumption an ERISA-governed "self-funded" health plan that provides benefits without using a health insurance contract?

Any insight, articles, or other resources anyone can share that would address the following questions: (1) Can different plans sponsored companies a part of the same controlled group stop offering coverage for weight loss medications?; (3) Can companies within the same controlled group decline to offer coverage for weight loss medications while others offer it? Even if they participate in the same welfare plan? (3) Can a plan limit or exclude new to market weight loss medications (non injectables)?

You will report credits earned in each year 2023, 2024 and 2025. It helps to see what the form looked like (https://www.irs.gov/pub/irs-pdf/f8554.pdf) to see what information is required, but renewals are easier using pay.gov. The place to start is here: https://www.irs.gov/tax-professionals/enrolled-agents/maintain-your-enrolled-agent-status Here is a fairly detailed description of the renewal process: https://accountably.com/irs-forms/f8554ep/ (my including this here is not an endorsement of their service). I agree the calendar-year dates for earning credits tied to off-calendar-year dates for the renewal application period and a different off-calendar-year dates for the expiration of the renewal makes it seem more complicated than it needs to be, but in our business most things that are tied to off-calendar-year dates seem more complicated than they need to be.

Thank you all so much for your responses. You are correct. The email Subject is IRS Enrolled Agent - Renewal Due by January 31, 2026, and it is addressed to "Dear Enrolled Agent." As I am not an EA, I assumed they had just confused this with an ERPA. But now I see the confusion was sending the EA email to ERPAs :). OK. Immediate crises averted. Thank you, Paul, for the link to check ERPA credits and renewal date. I am not so concerned about the credits to date because not all of them are reported directly anyway. When I renew, I report them then. What still confuses me is the cycle for restatements and CE credits. I don't see why it has to be so complicated. My ERPA expires 9/30/26 according to the website. It seems I need to submit my renewal application between 4/1/26 and 6/30/26. On that application, I am to report CE credits from which years? 2023, 2024, and 2025? See the screenshot from the IRS. It says 2023-2026, which is four years. So confusing. Thanks again for everything.

I, too, received the same message. I started receiving emails from the IRS related to Enrolled Agents (EAs) after having to make multiple requests to get my ERPA letter/card mailed to me after the last renewal. You can check your account for ERPA credits by year and your ERPA renewal date here: https://rpr.irs.gov/ptin?id=ptin_cecredits You have to have an ID.me account to login.

I got the same EA email and am a little concerned. Just seems weird.

Agreed, this is EA renewal which has a different cycle and different due dates

Are they asking you to renew as an EA, or as an ERPA? That intro you pasted here doesn't say enrolled retirement plan agent