Scuba 401

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About Scuba 401

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  1. company A and B were part of the same controlled group and had one plan which has last day requirement. company B splits off from A and establishes its own plan effective april 1 and mirrors all provisions. company A does not want to fund matching contribution to those employees that went over to the Plan B because of the last day rule. company B plan document credits prior service for vesting eligiblity and contribution allocation. company B wants to fund the matching contribution to those employees that deferred in the controlled group plan prior the spinoff and they want to give the match for the entire year. can they do this? document credits service with company A for contribution allocation eligibility and vesting. my feeling is the plan has a discretionary match so they can just say we are matching compensation deferred to all employees during the plan year or they can add specific language to that effect.
  2. this one has stumped the board...
  3. does incidental benefit rule apply if the plan sponsor rolls cash into profit sharing plan and purchases insurance from rollover money?
  4. sponsor underpaid RMD's to a few beneficiaries. IRS allows for a reduced fee for RMD failures but the form 14568-H says that RMD failures involving beneficiaries is not eligible for the reduced fee. I cant find this in the Rev Proc. anyone have any experience with this? my clients vcp fee would go up from 500 to 5000 and it only involves 5 or 6 beneficiaries. seems absurd.
  5. are assets of the investment company the same as the stocks or bonds contained within the fund?
  6. client is concerned that by putting mutual funds in his plan the individual securities inside the funds could trigger a PT or some type of conflict if he is in that industry or does business with any of those companies. i believe this isn't a PT but i am having trouble finding anything on point.
  7. expense was deducted from the plan assets. we want to give the money back to the plan if possible.
  8. our office set up an account improperly and its been charged a flat annual custodial fee. we want to reimburse the client for the overcharges. can we do so and can they put the money into the plan? alternatively can we just put the money back in the plan?
  9. the plan (relius nonqualified) used the definition for change of control from the reg. I was wondering whether you could just apply the provision by analogy. for example, in a change of control for a non profit the board of directors will change. that seems to meet the effective control prong of the definition.
  10. 409A regs have a definition I believe. it is going to be a trigger for distribution under the plan.
  11. can anyone think of what type of notice, if any, would be required to give to participants.
  12. I am trying to explain to a client how the change in control provision works in a 457(f) plan. can someone please explain how you apply the definition in the regs to corporations without owners or shareholders?
  13. I know the plan has to allow for in-service distributions and the participant has to eligible. lets say they are over 701/2 but a non owner. can they do an in-plan roth transfer?
  14. I am thinking multiple organizations that participate in the VEBA. a follow up question also...can a VEBA sponsor a 401(k)? the participants in the VEBA receive benefits which are paid through a W-2..they want to defer their benefits into a 401(k). is this possible?
  15. do they apply to VEBA organizations? I know nothing about 501©(9) so forgive my ignorance if this is a silly question.