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We use Broadridge and find they are less than receptive to reqests for changes in fund fact sheets.

I say no audit. They are still two separate plans. Just b/c some r/k puts everything under one "plan number" doesn't make it one.

Sorry, I too am a little confused. Trying to understand exactly what is occuring with the second group. But regardless, the test for affordability will be if the employee cost exceeds 9.5% of the income used to calculate. The additional compensation provided by the employer will increase the income used for calculation. By way of an example, the coverage gross cost is $500 per month/$6000 per year, the employee comp is $30,000. Employee writes a check for $500 per month/$6000 per year and the employer increase the comp by $500 per month, to a total of $36,000 per year. If this is what you are describing? If so the test would be if the $500 per month/$6000 per year paid is 9.5% or below. At $36,000 per year the 9.5% threshold would be $3,420.

I can't comprehend why the employer would do it that way. But I don't believe you can offset the cost by the additional compensation. The regs don't even allow you to take into account that cafeteria premiums are pre tax. They need to take a look at what they're doing and why and revamp it for 2016, IMHO.

ok - I found this on the IRS website under the "5500 Corner" scroll down to 5500-EZ... Attached is the form they reference that does have a phone number in the header. Here is the link: https://www.irs.gov/Retirement-Plans/Form-5500-Corner hope this is helpful

For a 2016 beginning of year participant count for a plan that terminated in 2015, I would say the zero balance people are not included. Plan termination is a distributable event (assuming no alternative defined contribution plan) and unless you have really strange plan language, those with zero balances are deemed to be distributed when the distributable event occurs. For those with balances, they stop being participants when they are paid in full after the plan termination.

We do the Schedule A the same as for a DB plan or any other plan.

Wouldn't one month's advance notice for each week of shutdown be a reasonable standard for the IRS to be expected to meet? Certainly, one day's advance notice for each week of shutdown does not appear adequate. But for this discussion thread, who would have known to watch out for this? So mandmeickhoff@msn.com, you have my thanks!