kcbirm

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kcbirm last won the day on March 8

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About kcbirm

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  1. I don't see any reason that you can't do it now.
  2. It all comes down to what the document says. I could certainly see this being an outcome, in fact the likely outcome, unless steps were taken in advance to keep them out. It's possible the document could have been drafted to accomplish all your goals, but that's water under the bridge at this point, you have to go by what the document says.
  3. I agree with Bill. The ER may end up making a contribution for the earnings if it was their fault. If the RK screwed up, they should make up the lost earnings.
  4. From the EOB Last day of work is usually the date of retirement. Suppose an employee’s last day of work is December 31. Is his date of retirement after that date, which would push retirement into the next calendar year and postpone the RBD by one year as well? According to the IRS, the determination of retirement date is one of facts and circumstances, but normally the last day of work is the date of retirement. The IRS explained its position in a Q&A session with the Taxation section of the American Bar Association held on May 9, 2003. See Q&A-12. However, if the employee returns to work on a sporadic basis, or there is other evidence of retirement occurring on a later date, then there may be a later retirement date for RBD purposes.
  5. What time did he get off of work?
  6. not likely, no
  7. The SIMPLE has to be the exclusive plan of the employer for the whole year, so I don't think you can do a merger into a 401k.
  8. IAW Lou and Tom. An additional $4,000 can be recharacterized as catchup, bringing the total PSP /other sources allocations up to $39,000.
  9. IAW Belgrath. The participant's 415 limit is $53,000, of which $18,000 has been used as deferrals. He can get another $35,000 in other contributions.
  10. So I assume the plan's enrollment form and/or procedures didn't allow for a Roth election. What would have happened had someone read the SPD and elected Roth? Seems to me the best fix is to amend the plan and have the Roth effective date be the date it was truly effective.
  11. Maybe this is a controlled group an your document automatically covers all employees of all employers within the controlled group. I think that's fairly common, so you may not have an issue at all.
  12. Trying to straighten out the earnings on something like this takes a lot of unnecessary time and effort given the amount. But that said, I think the basic premise is to put everyone into the position they would have been in had the error not been made. That means taking the money and the associated earnings from the participant who received it in error. And depositing the amount plus associated earnings into the right persons account. The earnings to the right person would be based on their investments. The gains/losses from the person who received the erroneous amount should be actual as well. This is what you would likely do if it was a significant amount, like for example depositing someone's rollover account into the wrong person's account. I don't think the deposit was late, and I wouldn't be doing a VFCP filing or reporting it on the 5500.
  13. I have a hard time imagining a scenario where it is other than the insured.
  14. I would just make the effective date for deferrals 4/1, and then any eligible participant at that date could start deferring. I assume your document will allow deferral changes at least quarterly, so that people can "enter" on 4/1 by changing/implementing their deferral election.
  15. EACAs are seperate from QACAs so yes. But a basic SHM is an enhanced QACA anyway, which would allow you to have two year cliff vesting on the match.