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Yup, that's why our plans had automatic rollovers for $0 - $5,000. I really miss 100% tax withholding

It's just crazy that there is no self correction option, even for small amounts. Frankly I thin there should be a self correction option for deposits that are late by less than a month for example regardless of size. Maybe they will figure that out!

looks like the IRS has decided we don't have to answer all those extra questions in 2016.guess they still haven't gotten approval for them yet! from their website: https://www.irs.gov/retirement-plans/irs-compliance-questions-on-the-2015-and-2016-form-5500-series-returns IRS Compliance Questions on the 2015 and 2016 Form 5500-Series Returns The IRS added compliance questions to Forms 5500, 5500-SF, 5500-EZ and Schedules H, I and R. The IRS has decided that filers should not answer these questions for the 2015 and the 2016 plan years when completing the forms: •Form 5500 Preparer Information (page 1 bottom) •Schedule H ◦2015 plan year: Lines 4o-p, 6a-d ◦2016 plan year: Lines 4o, 6a-d •Schedule I ◦2015 plan year: Lines 4o-p, 6a-d ◦2016 plan year: Lines 4o, 6a-d •Schedule R ◦2015 plan year: New Part VII (Lines 20a-c, 21a-b, 22a-d, and 23) ◦2016 plan year: Part VII (Lines 20a-b, 21a-b, and 22a-b) •Form 5500-SF ◦2015 plan year: Preparer Information (page 1 bottom), Lines 10j, 14a-d, and New Part IX (Lines 15a-c, 16a-b, 17a-d, 18, 19, and 20) ◦2016 plan year: Preparer Information (page 1 bottom), Lines 14a-d, and Part IX (Lines 15a-b, 16a-b, 17a-b, 18, and 19) •Form 5500-EZ ◦2015 plan year: Preparer Information (page 2 bottom), Lines 4a-d, 13a-d, 14, 15, and 16 ◦2016 plan year: Preparer Information (page 2 bottom), Lines 4a-d, 13a-b, 14, and 15 Page Last Reviewed or Updated: 05-Oct-2016 .................................. good grief, I can hear you crying and moaning way down here in Florida, and I've hardly even posted this. Get over it and deal with it already!

IMHO I don't think the 100% withholding was ever really sanctioned (so it didn't really "go away".) Many years ago It was a way to get the balance out of the Plan and the funds to the participant, who hopefully got a nice surprise when they filed their taxes. If memory serves, somewhere along the line it became stated that it was not a valid way to remove a lost participant account from a qualified plan.

a plan has to pass nondiscrim testing both with and without the QNEC (1.401(k)-2(a)(6) and so, while testing the plan without the QNEC (if cross testing) you have to satisfy the gateway without the QNEC. you cannot say "Fred received a 5% QNEC enough to satisfy the gateway. I now perform my tests with and without the QNEC"

Our clients would fire us if we attempted to charge them anything for this. And honestly, I feel like this is why they hire us. Rightly or wrongly, we would just pay the penalty in this situation. Not trying to be sanctimonious, that's just how we would handle it.