Leaderboard

And keep in mind that the type of personality it takes to sell your services is very different than the type of personality it takes to do the detailed work. Very few people can handle both well!

Yes

While there may be a concern with a possible disparity in potential earnings between the NHCEs and HCEs if deposits are not made proportionally throughout the year, I am not aware of any requirement that a single deposit must satisfy benefits testing.

Don't forget that E&O insurance!

I strongly recommend you attend the NIPA BMC conference in January in Scottsdale AZ. It focuses on the business side of running our firms. I'll reiterate MoJo's advice - nothing happens unless you can get clients. Presumably partnering with the CPA firm will be part of your marketing strategy, but selling is key. And it is a relationship business. You need to nurture relationships with advisors, CPAs, attorneys and recordkeepers. People like to do business with people they know. Don't underestimate the time and effort involved in this. Those who are good at it make it look easy, but it's not. Good luck.

Why chance it? Pay minimum wage for 1,000 hours.

If I were advising the employer, I would advise it to pay the money into the plan, with some reasonable interest factor. Probably a breach of fiduciary duty in causing the money to be paid to the wrong person (lack of sufficient internal controls, etc.). The employer can then attempt to collect from the individual to whom it was paid, but the employer should face up to the fact that it may have to suffer the loss if it can't collect.

From IRS Notice 2013-74: Q–7. Would a plan with an ongoing qualified Roth contribution program violate § 411(d)(6) if it discontinued in-plan Roth rollovers? A–7. No. An employee’s ability to make an in-plan Roth rollover is not a section 411(d)(6) protected benefit. However, an amendment to eliminate in-plan Roth rollovers is subject to the rules in § 1.401(a)(4)–5, relating to whether the timing of a plan amendment or a series of plan amendments has the effect of discriminating significantly in favor of highly compensated employees or former highly compensated employees.