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Showing content with the highest reputation on 07/19/2021 in Posts

  1. AKowalski

    Rev Proc 2021-30

    Rev. Proc. 2021-30 TOC.pdfHere's an unofficial TOC with pagination.
    2 points
  2. The amount shouldn't matter to this discussion. The client normally relies on the 7 bday safe harbor (deemed to be segregated at the earliest date), the transaction in question took 8 bdays due to unusual circumstances. The question is, did the unusual circumstances cause a small delay during the 7 bday window to make it 8 bdays, or was the 8th bday the earliest time it could be deposited due to the unusual circumstances? If its the former, it should technically be reported on the 5500. If it is the latter, I think you have a reasonable argument for calling the deposit timely and leaving it off the 5500.
    1 point
  3. From the 5500 instructions (emphasis added): I understand the reference to "manual" signature to mean that is must be signed by the person's own hand. If they want to sign electronically, the only acceptable option is for them to obtain EFAST credentials. For what it's worth, most of our clients obtain their own EFAST credentials and sign their own forms. It is a bit of pain the first year but after that they usually don't have any problems.
    1 point
  4. Bird

    Insurance Transfer

    Why would anyone want to do such a thing? It makes no sense to me but maybe I'm missing something...anyway, the first thing I'd do is try to dissuade him from doing it. Having said that, "transfer" in a plan context really means "contribute" (as in a rollover) or "buy" (as in the plan buys it from him). There is no simple "transfer" (as in "let's just slide this asset into a plan"). The appropriate value is the interpolated terminal reserve - I doubt that is $0 - and as I see it the most likely scenario would be a purchase by the plan.
    1 point
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