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If the recordkeeper won't take a payment directly from the participant, he or she could give a check to the employer to deposit along with their regular deposits.

They are required by law to have the records, but in my experience they rarely do and even more rarely to they understand that they are supposed to. If you can get them to understand that requirement, they can press the record keeper or TPA to get them the information.

No question about it, it is the PA's responsibility. And they have to have the records, they are required to by law. If they don't, their service providers do. If the service providers don't... Can the PA even execute what is in the QDRO if it has no records? I just don't see how.

Scheduled to be published tomorrow. Looks like we can go back to using forfeitures to fund safe harbor contributions, as long as your plan allows it. Fortunately, our VS document has the phrase "unless provided otherwise under IRS guidance" at the end of the sentence about not using forfeitures towards SH contributions. https://www.federalregister.gov/documents/2017/01/18/2017-00876/definitions-of-qualified-matching-contributions-and-qualified-nonelective-contributions

If you don't think your document allows you to use the new rule, you should ask your document provider. It's something they should be looking at now, anyway. If the document language is a problem, you can ask them if that is something that can be fixed retroactively with an interim amendment. Our VS document language is clear, so I haven't gone down that road.

The MSP rules make it generally impossible for a 20+ employee employer to reimburse Medicare premiums, with or without a QSEHRA. It may work for employers with fewer than 20 employees.

If he owned 100% of both entities there is no way to escape aggregation.

And to further shorten the list, at least visually, click the Condensed link in the upper right. It shows only thread titles. Expanded shows titles and the first two lines of the response.

What I miss is being able to just see topics that have received posts since the last time I was here. An undifferentiated list of unread posts makes it harder to keep up with the newest posts (and I consider it a disadvantage that when I do look at a post from the list of unread posts, it disappears when I go back to the list and I can't even tell what I am returning from). I liked the old feature that showed threads that have since been updated in bold and those whose latest post was read by me as unbolded. Is there a setting that will show things like that?

Press your plan administrator. They should have plan-level reports somewhere. That report should include a participant listing of accounts. They can pull your records from that. Maybe press John Hancock more, too. Just because they don't have immediate access to statements older than 2 years doesn't mean they can't get that information for you. I mean, the data just doesn't get wiped away. Ask to talk to a supervisor, and then a manager and then the manager's superior if you do not get satisfaction. To the group: who is responsible for calculating earnings in these cases? The plan administrator? The participant? I would think that it is the Plan Administrator, as they are approving the amount to be moved with the record keeper.

IRS has started notifying employers it suspects were Applicable Large Employers for 2015 but who have not filed 2015 Forms 1094-C and 1095-C (see redacted letter 5699 attached). I'm wondering what "records" iRS used to make this determination, perhaps the filing of a threshold number of W-2s in 2014 that might indicate ALE status for 2015? IRS Letter 5699 Request for 2015 Forms 1095-C_15342356(1).PDF

I don't understand your point. It only "affects" your 941s and the W-2 and "income tax filing" (I assume you mean the employer's income tax return) in the sense that you paid the employee less in compensation in 2016 than you should have paid, and therefore the unpaid amount should not be reflected on any of those filings.

A payroll administration error, but not a tax error. Employer owes employee money. If it is paid back in 2017, it will be subject to tax and associated withholding in 2017. It's no more complicated than that.

Look at me. Helping instead of mooching for a change.