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Showing content with the highest reputation on 11/24/2020 in all forums

  1. BG5150
    I had a brain fart. I was just discussing with a co-worker about a client who is an employee of a company and he has his own plan (un-related). So he has two 415 limits.
    1 point
  2. Luke Bailey
    OK. I missed that, Bill. Thanks for correction You aggregate all DC plans of same employer and have just one limit. 1.415(f)(1)(a)(2). 1.415(j) provides rules for aggregating plans of same employer that have different limitation years, but here if there was no contribution for LY of plan 1 ending 4/30/2020, you would get a pass under 1.415(j)(c)(2), so I think you are right, Bill.
    1 point
  3. Bird
    We would restate and use the new EIN; probably include the sole prop as an adopting employer or at least credit prior service.
    1 point
  4. AlbanyConsultant
    There were... things in the old plan that we wanted as much separation from as possible. I wish we didn't have to do it this way, either. The CPA decided that they were not going to put in a contribution for the 4/30/20 PYE after all (I don't know why). I feel like it is less necessary to reduce the calendar 2020 limits in the new plan because there is no benefit being given on the 1/1 - 4/30/20 compensation in the old plan.
    1 point
  5. BG5150
    Also, what happened in the years before? You have to start at the beginning. You track sets of deferrals (Jan to Sep and Oct to Dec) and just draw a chart showing where the deferrals overlap between calendar and plan years.
    1 point
  6. Mike Preston
    Just as accurate.
    1 point
  7. Luke Bailey
    Personally, I always recommend a crystal ball.
    1 point
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