Leaderboard

Gilmore - I don't think there is one. thepensionmaven - after-tax voluntary contributions only have their basis post-tax. The earnings on it are subject to taxation when distributed. Usually if I have someone who has take the time to do an after-tax contribution, they know they immediately have to convert it to Roth (which results in zero additional income since the after-tax voluntary was already taxed), and then the money is considered Roth, and the earnings occur post-tax as well. If part of a 401(k) plan - they are not Roth IRA conversions, they are Roth conversions within the retirement plan. The participant makes an election (usually similar to filling out and signing a distribution form) requesting the conversion of plan money from non-Roth to Roth. Yes, there still might 415 excess, and an ACP failure. Those are completely separate from the conversion request. I'm still curious to know how the ACP passed with O% for NHCE, and X% for the HCE.

What was the HCE ACP average %? How do you have a NHCE ACP of 0% pass?

Did you verify that the plan doesn't already exclude collectively bargained employees? I typically put that exclusion in a document even if the employer doesn't currently have union employees. The question deals with a mid-year amendment to a safe harbor plan. While union employees could have been excluded from the plan (or from the safe harbor), the safe harbor rules prohibit certain types of mid-year amendments. These rules are in 1.401(k)-3(e)(1) and additional exceptions are described in Notice 2016-16. Unfortunately, the notice says that mid-year amendments to narrow the group currently eligible for the SH contribution are prohibited (III.D.2). The regs have a provision that allows reducing or suspending the SH contribution mid-year (1.401(k)-3(g)), but under the situation described, I don't see how the plan could remain SH for the year. Based on prior discussions, if the plan provides a benefit to union employees that was not included in the CBA, there would be labor law issues.

Agreed with previous posters, but posing one question. Is the idea that the school will pay the employee portion only for the retiring superintendent, or for all retirees for the period before the superintendent reaches Medicare age? I'd check the nondiscrimination rules in either case.

austin3515, my guess is you're overthinking this. The IRS cover letter says they'll only use for research, and Westat is an independent research organization. Having said that, it doesn't seem to promise that the answers will be confidential and not shared by Weststat with IRS. It might behoove you or your client to call Weststat at number provided and seek reassurance as to use of data. Years ago there was a much more intrusive survey that was sent around, as you may recall, and my clients did not seem to have audits as a result.

I agree with RBG above. When I read my study materials, I outline them, in a notebook, by hand. I then answer the questions in the study guide, and find that my hand written notes usually have covered all of the study guide answers. (If not, then I missed something important that I need to go back over.) Before I take my exams, I read and re-read my hand written notes, go through the sample questions and then do the sample tests. It really does make a difference to write it all down!

@Pam Shoup suggestion above is great. It needs to be done by hand rather than typed on a computer. Studies have shown that doing it by hand increases memory retention significantly. When I was in law school I took all my lecture notes by hand and I did my outlines by hand before I put them into a word document. I do the same thing whenever I study for a designation or read a new proposed rule or law change. For actual studying I do something like this Week 1 Read Ch1 (or part 1, section 1, whatever), then outline Ch1 on the second read Week 2 Read Ch2 , then outline Ch2 on the second read, study Ch1-2 outline Week 3 Read Ch3 , then outline Ch3 on the second read, study Ch1-3 outline Do this until you have outlined all of the required material. The outline should mainly focus on the learning objectives from the syllabus unless there are new things there that you also feel are important. Since different sections are weighted more or less on the exam, you can substitute Ch1 above for whatever section is going to be used more on the exam, that way you read that outline each week and should know it well before the exam. There is no point in doing a 5 page outline on plan loans and a 1 page outline on testing if you are going to get one loan question and 10 testing questions...

What I do with my staff is have them identify those things that always seem to trip them up. I then have them write down tips on those things on a sheet of paper, usually in a grid format. For example QACA, EACA, ACA across the top and things like vesting, auto esclation, etc. down the side. I have them do that writeup over and over again until they can do it from memory. On the day of the exam, the testing center will give you blank paper and a pencil. Before they start the exam, the candidate writes up their tips/grid on the blank paper. Then when you get to those questions, you have something in writing to look at to help keep things clear in your mind. Do the practice exams over and over again, as some of the questions from those will appear on the final exam. Also, is there anyone else in your office that you can sit down with? For example, I have my ERPAs do training sessions with my QKA candidates on things they needed some additional guidance on.