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FYI, the Directory of Federal Tax Return Preparers with Credentials and Select Qualifications lists 363 ERPAs. The list shows name and address, and can be searched by name or proximity to zip code. You can have a party and invite all your ERPA neighbors 🤣.

for American Trust Retirement (Remote)View the full text of this job opportunity

I think I know the answer but I wanted to check the following: Existing 401k plan for a sole-prop. The election for deferral amount had to be made by 12/31/2025 for 2025 as it cannot be done by 4/15/2026? After year end only applies for new plans. Am I correct?

I know of several people who are dropping (or have dropped) their ERPA designation - in their opinion, it simply isn't worth the hassle.

I doubt it. Its more likely that the process is just chaotic and full of issues. It has been since day one.

I renewed in July, 2025 for the 22,23 and 24 years. I showed the proper number of credits. First IRS said they never received my renewal and was placed on inactive. I know they received as they cashed my check I was told I'm 16 credits shy as well as 6 Ethics, which I am not. I wrote a "reasonable cause" as I had an 6 month recovery from two torn retinas, and asked for either a waiver or extension to obtain the necessary credits - just in case they are correct. How would I show the I completed and received the "additional" credits A new Form and go back to 2022 and list all credits, as well as pay another $140, or write in and tell them I have completed and show my backup? In the meantime I was told by an auditor that I can use Form 8821, but obviously can not represent myself as an ERPA until this is straightened out, which, pgiven the furlough could take another 90 days. Are they doing this to others in the hope that they can reduce the number of ERPAs (which is already ridiculously low)?

Just thoughts. Generally speaking, group health plans are not federally required to cover weight loss meds. Most of the plans I deal with would not cover them if simply for weight loss but might cover them if for some other medical issue, e.g., to control Type 2 diabetes or high blood pressure. Most of those plans would require preapproval. Employers, especially those with self-insured plans, have discretion to dermine their drug formulary. Since self-insured (and possibly one day with fully insured) offering the meds to one group versus another would be permitted if not discriminatory under §105(h). If different between plans, do the separate plans satisfy 410(b) coverage testing? If different for different groups within a plan, is the approach structured to meet 105(h)? how does the employer classify the employee groups? etc....

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?