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I have never seen such an arrangement. If the participant's investment options are restricted to the plan's core menu, would the services of an outside advisor still be plan-related expenses?

Yes.

Certainly. Consider a plan with a brokerage window or self-directed brokerage accounts. Whenever a participant selects investment alternatives outside the plan's investment menu, they are going to end up using plan assets to pay advisory fees on those investments.

Yes this will work. Payments made before the due date of the tax return will count for that taxable year, so the first payment could even be made in 2021 on behalf of 2020. We haven't seen 8915-E yet, but Notice 2020-50 details repayment with examples. CRDs are subject to voluntary withholding, so participant can waive the 10% withholding Notice 2020-50.pdf

My take Can You Convert A Coronavirus-Related Distribution To A Roth IRA? Comments welcome

Just be careful with this because the employer has to monitor EACH employee separately and ensure they know when they hit 1000 hours. The larger the number of employees, the harder that is.

Loan default can NOT be treated a CRD. Loan offset CAN be treated as a CRD. If the participant is a qualified individual and the loan offset is treated as a CRD, 10% penalty is waived and the amount is eligible for 3 year income inclusion. Simple example $20,000 total balance (10k loan, 10k cash) Plan terminates and the loan is offset The $10,000 offset is not subject to the 10%, and can be taxed over 3 years and repaid over 3 years (1099 code 1M I think, also reported on Form 8915-E as a CRD) $10,000 can be rolled to an IRA (1099 code G)

As the saying goes, it doesn't matter till it matters. Meaning when you get sued the first and obvious conclusion is that the problem was you wore both hats. In other words if your moral compass doesn't rule it out, your fear of giving your legal adversary low hanging fruit should do the trick.

Bad idea. The "audit" function audits controls - which may include processes handled by the TPA. It's a quick way to permanently lose your authorization to conduct audit services (and the DOL is looking hard at audit firms right now).

The one and only time I worked for a CPA firm that did TPA work through a subsidiary they never did both. The closest I saw was we would prepare the Form 5500, 8955-SSA and SAR for a plan they did the plan audit. It was my understanding it was the CPA rules for independence that was the issue not any kind of TPA ethics rules. But I can't quote anything even though I am a CPA. I just wasn't involved with those independence questions by management at the CPA firm.