Santo Gold

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About Santo Gold

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  1. Employer A is part of a controlled group consisting of one other larger company (company B), but has a great deal of autonomy from the CG. They are permitted to take part in Company B's 401k plan. However, The owner of Company A is an HCE in the Company B plan and keeps getting hit hard with 401k returned deferrals since Company A plan is not safe harbored. Can company A start their own safe harbored 401k plan immediately or do they have to wait until the start of a new year to have a new plan effective? Would anything need to be done in Company B plan to then exclude Company A employees from being eligible for Company B plan? I do not think that having Company A employees eligible for both plans would be desirable, so I would assume of a Joinder Agreement allows Company A employees to be in the Company B Plan, it would just be a matter of changing that agreement? Company A employees have money in Company B plan. Once Company A has their own plan, can Company A employees move their money out of Company B plan? Would that be via distribution or transfer? Since no one is terminating employment, I would think a transfer out of B plan to A plan would be the only option. Both plans would have to be tested together correct? The contributions in A plan might be better than B plan, but if B plan has more HCEs, there is a decent chance both plans pass 401(a)(4), would you agree? Thanks
  2. Can an individual age 50 have a 457(b) deposit of $24,000 in that plan as well as in a 403(b) plan? Thanks
  3. Thanks to all for the great replies. Would rolling it into a USA IRA be an option, or would similar restrictions apply? Thanks
  4. We have an employee in a current USA 401k plan who has a large retirement plan account in a Mexico-based retirement plan from his previous employer (non-related to the current employer in the USA). The USA plan accepts rollovers from other plans, IRAs, etc. But since the Mexico plan is not a 401(a) type of account, I assume this could NOT be rolled over into the USA plan, is that correct? Any way he could roll it into the USA plan? Thanks
  5. I know this has been asked before, but could not find it (easily) on a prior thread, so... Employer wants to have a safe harbor plan eff 1/1/17. Its 12/1/16 and the safe harbor notice is due. Or is it? Is there an exception to the 30 days before the plan year starts requirement for start up 401k SH plans? We'd like to have this effective for all of 2017, but there a some plan design questions not settled yet so we cannot have the document signed by 12/1/16. Thanks
  6. Can any company that is part of a controlled group adopt a SIMPLE? If so, would it follow then that either all members of the CG MUST be eligible for the plan or that all members are included for testing purposes, even if not eligible to be in the plan (which would seem to take the simple out of SIMPLE). Is it even permitted for all members of a CG to adopt a single SIMPLE? Thanks
  7. Is there an easy online way to electronically pay the 20% amount withheld on a cash distribution? We have a small client who has brokerage accounts for the people in the plan. This is the first time they will have a cash distribution. The brokerage account will not pay the 20%. The client does not want to open up a bank account for what will likely be a 1 time only transaction. Payroll (correctly) will not accept deposit of the 20% and then transmit it to the IRS. If the 20% was under $2,500, it is allowable to pay it at year end when filing Form 945. But, the amount is well above that. I've read on other post that Penchecks could work. But is there an IRS link that could be used to pay the tax online? Even if it costs a few $$$, that might be OK. Thanks
  8. I was able to file it as is, but when I review my submissions ("filed" forms) for all clients, under the STATUS column, it says "filing received" for all of my plans, but this is the only one that I can still "click" on, and when I do, I get the Z-003 message. So, based on what Laura A has stated, this is a warning, not an error, the filing was "received".... is there anything for me to complain about other than I don't like having a filed form with a warning message attached to it?
  9. This is what DOL told me as well, for the 2015 filing. I may try "kicking it upstairs" when I call back again.
  10. This was a 2015 filing. I am sure I have had plan name changes in the past and this never came up. Sounds like it is new for 2015.
  11. I meant to say the 5500 software DID NOT flag this as an error. Its the DOL/EFAST that once it was uploaded to that site, indicated there was a problem.
  12. The 5500 software did flag this as an error. Once it was uploaded to EFAST we validated it and the error message keeps catching it. As I said, I talked to someone at the DOL/EFAST about this and twice he confirmed that in fact this is a correct error message (Z-003). But, I know that he is not correct, at least when he says that changing the plan name means that this is a new plan, therefore needs a new plan number, need to terminate the old plan, etc.
  13. Yes, I did check that the employer name changed. The error message is referencing the plan name being different though. No place to check for that......
  14. Employer ID number did not change.
  15. And that is exactly what was done with the PPA document restatement for this 401k plan. We changed the company and plan name. But after talking to the DOL today via the EFAST website, I was told that the Z-003 error message pertained to the change in plan name and, sounding rather convincing, pointed me to page 15 of the instructions which would state that the plan name must match the plan name from the prior year's return. The instructions do in fact state that the plan name should match last year's plan name and I did not see anywhere (in the instructions) that an amendment to change the name is acceptable.