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Showing content with the highest reputation on 07/22/2020 in Posts
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403b pre-approved non-amenders
John Feldt ERPA CPC QPA reacted to austin3515 for a topic
Has anyone heard if the IRS is going to come out with any non-amender program as a means of allowing these non-profits to correct the fact that they did not restate by 6/30th? Already have someone in that situation (not a client I should point out!). It occurred to me that they did away with all the $325 VCP options so I do wonder if there will be anything...1 point -
I think your answer lies in EPCRS. The sponsor has two options: Make a QNEC on behalf of the NHCEs at a level that makes the test pass --OR-- Do a refund and also contribute a QNEC in the amount of the gross refund.1 point
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I don't think I have an issue with the form of payment, assuming it is permitted by the plan document, but how does this solve his excess assets problem or allow him to terminate the plan?1 point
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