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Everybody's administrative software (DATAIR, ASC [as shown above by C. B. Zeller], etc. should have the ability to generate the factors necessary to produce the disclosures. Here is a screen shot of my program confirming the 252.208 factor.

One of my first steps would be to ask to see how the existing account is titled. Expect the worst - could be "...IRA." If it is "XYZ investment company, custodian for ABC 401(k)" then odds are there is a document and the advisor just doesn't know it or doesn't know where to find it.

CARES wasn't extended, the last day for a CRD was December 30, 2020. The qualified disaster distributions in CAA21 did not include any area where a major disaster had been declared only by reason of Covid-19. You needed something like a hurricane, wildfire, tornado, etc. If you were trying to get a distribution just because of Covid, you were out of luck after December 30, 2020.

Insist on him getting a TIN now that it is known the SSN is invalid. Period. For some reason IRS comes down like a ton of bricks on 1099-R payors reporting distributions with invalid SSNs, this after years of accepting payroll returns, tax withholding and W-2 filings using those same SSNs. IRS first assesses fines on the payors, and it takes a couple of years to get them waived, so they payors routinely have at least two or three pending assessments open with IRS. Basis for penalty abatement is the payors have no way knowing the SSNs were invalid, but that's not the case here.

"Retirement" in a plan is severance of employment on or after Normal Retirement Age.

There's an extension to that I've used in dealing with clients: "Pigs get fat, hogs get slaughtered, and attorney's eat bacon." Translation: If you want to do something, pay me now (to fully vet the proposal), or pay me much, much more later (when it blows up).

My position is that we inform the client (on the record for CYA purposes) of the reasonable compensation requirement and that it is up to the client, hopefully with formal input from their accountant and/or legal counsel, to determine reasonableness. If it flies (with or without subsequent scrutiny) then great, and if it doesn't you have the "I warned you/I told you so" in your defense - not that a legal defense is needed. And YES - that is always sound advice!

If I mention it, the question back is typically "how much do I pay them?" I explain that I can tell them the impact on plan contributions for various levels of pay but I recommend they consult with their CPA regarding the "reasonableness" of compensation, since they want to deduct it on the business return. I also tell them if the IRS disallows the deduction for the kids' wages it will then disallow their related plan contributions as well, and this can lead to all sorts of unpleasantness. I will usually end this part of the discussion pointing out the 15.3% payroll tax they incur and remind them that "pigs get fat, hogs get slaughtered. Don't be a hog."

Well, as a TPA it's not my place, but whenever we are discussing wages to family members I tell them the pay has to be reasonable for the services rendered. Now, as an employer who did this myself with 4 kids, one year I actually got a letter from the SSA questioning the wages to my youngest daughter based on her age. The kids did come into the office at least a couple of times a month to fold, stuff and mail billing statements and the occasional mass mailing (I'm old - snailmail BITD). I was paying them more than minimum wage, but not excessively so, at least not IMO. IIRC I kept them under the 1040 filing threshold. Absent use of likeness, I'd not be comfortable with $24K for a 6 year old, that's for sure. I generally discourage letting really young kids into the plan, even if there are no NHCEs. One reason is the reasonableness issue, the other is I'm a big fan of having the parents gift the kids enough money every year for a Roth IRA contribution assuming the kids have earned income.

No.