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If the site will give you single life APRs and a 100% J&S APR, you could use those to calculate the 50% APR. Just let me dust off my life contingencies notes here ... Ax = Single life APR for life aged x Ay = Single life APR for life aged y Axy = Joint life APR for lives aged x and y 100J&S = Ax + Ay - Axy Axy = Ax + Ay - 100J&S 50J&S = Ax + 0.5*(Ay - Axy) = Ax + 0.5*Ay - 0.5*[Ax + Ay - 100J&S] = Ax + 0.5*Ay - 0.5*Ax - 0.5*Ay + 0.5*100J&S = 0.5*Ax + 0.5*100J&S = 0.5*(Ax + 100J&S) So, take your primary annuitant's single life APR, add the 100% J&S APR, and divide that by 2 and you should get the 50% J&S APR. I spot checked this with a few randomly selected ages and mortality/interest assumptions from my software.

Its been a while since I have done one, but you can do one Form 5330. Use 2020 Form 5330 On description of PT put something like "late deposit of employee contributions - see attached summary. Noe: Value in column (d) is cumulative for 2017-2020" Attach a summary for all years.

Not many people know this, but the Staff of the Joint Committee on Taxation published a description of the CARES Act, available on their website: https://www.jct.gov/publications.html?func=startdown&id=5256 See pages 18-19 of the PDF regarding the impact of the 2020 RMD waiver for participants whose first RBD would be April 1, 2021. (tl;dr: The participant's "first" RMD due by April 1, 2021 is waived. Only the "second" RMD is required and must be distributed by December 31, 2021.)

I agree 100% with Luke Bailey. This individual is not a Qualified Individual. Spouse makes him or her a QI only if the spouse has tested positive for COVID-19 by a CDCP approved test.

The government agencies have never provided much helpful guidance. The IRS has said in a number of forums over the years that prime plus is not commercially reasonable but many, many loan programs use it. A commercially reasonable rate is required. One comparable type of loan is the compensating balance loan which often is discounted. I have heard IRS presenters say the rates from these loans were too low.

Actually both of these sites calculate Joint & 100% but neither appear to calculate Joint & 50%.

While I agree with the end result that this is (probably) not a COVID loan situation, I disagree that you need a specific reason for the loan. It doesn't matter. If you are a "qualified individual" you can get the money (assuming - you otherwise are able to get a loan). If the father was a "dependent" - then I would say it qualifies. Period.

Yes, I see your point. I misspoke

No, because that would be discriminatory. Why would he want to prevent active EEs from taking advantage of it if they are qualified individuals? If the plan does not adopt the plan for CARES then they will be subject to the 10% premature distribution penalty.

I think the first piece to solve is how much does the owner want to participate? How much does owner want to defer? Can he get to that number? Is the owner age 50 or greater? Depending on that answer is how I decide to move forward. You may have a plan that becomes TH the first year. all non-Key* I'm really smelling a 3% safe harbor is best. The cross testing is good option, but not giving employee 3 PS is not going to be a smooth as you think. Especially if plan goes top heavy.

Why not profit sharing? Less restrictive than a match formula - you wouldn't have to give anything to EE 3.

I've never had anyone opt for an annuity but have needed to provide the estimates before. One "comforting" tool is the Schwab Income Annuity Estimation at https://www.schwab.com/public/schwab/investing/accounts_products/investment/annuities/income_annuity/fixed_income_annuity_calculator

OK - as the handle says, I'm retired, but still reading/interested ... so am a little late in adding my 2 cents, since the weather was nice and the tractor beckoned. As a TPA firm owner, our policy was that when someone wanted to move to a new provider, we held the door open for them and provided them with whatever documents they needed at no charge. We were able to do this because all of our files (40+ years) were digitized as pdf's, organized and easy to access. We undertook the digitization project for disaster recovery purposes - digital storage is dirt-cheap - but the digitization was quite an undertaking. Fortunately, our interns did a great job of scanning (and checking every scan) and they were well-paid for it. Even when we were paper-based, we were the repository of last resort for plan information, whether it's compensation history, confirmation of an old distribution for an attorney handling a participant's estate or that signed amendment required as a condition for a favorable Letter of Determination for an IRS audit ... we felt a responsibility to keep the info and folks that needed the info were extremely grateful that we had it. It wasn't clear whether pensionmaven's new client owed the prior TPA for services - if we had a non-paying client, we'd still furnish plan records for work that was completed/paid - at no charge. On takeover cases, our general rule was to call the prior TPA (not email, not fax - a phone call) - often a phone call helps you to better understand what you're getting into with the new client - and by making it personal, the former TPA may relent on the copying charges. I don't know about your market, but in our market, most of us were cordial, friends and willing to help each other. FWIW Peter

1. Required, in some form that complies with 401a9 2. At some point. End of 2022 as of now. 3. See #1. Why do you think you are late?

In a DC plan you can't self-annuitize, so as Andy mentions, the insurer you prudently choose gets to control those factors.

Does this help?

Nor have I.

They could exclude from match (subject to coverage) but not salary deferrals because of universal availability, is my opinion/understanding.

I wouldn't want to bet on how well your creative interpretation will work on the IRS with a plan document that calls it a SH contribution, applies all of the requirements of a SH contribution to it and includes it in the SH provision section, like our VS document does. Also, from Derrin Watson's COVID-19 Q&As: http://www.erisapedia.com/static/Covid19Webcast2020_04Questions.pdf (page 18)