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There is zero justification for reducing the annual 401a17 limit in this situation. $290,000.

Last day of the seventh month, to be exact. So if payout was any time during the month of May, for example, the final EZ filing is due by 12/31 absent filing an extension (which would also be due by 12/31). And a final EZ filing is due even if the plan never exceeded $250,000 and never filed an EZ before.

There is no clear guidance regarding this that I know of. I think the answer is "yes". I base this on the fact the rules tell you when to start. The plan document tells you when to start. They don't ever tell you when to stop. I THINK the ERISA Answer Book opines with a "yes" also. To be clear I have never found a cite one way or another so I can imagine a reasonable case for "no" but that is not the one I favor. So far most of my clients have gone with my "yes" when I layout the two possibilities and the reasons for each answer.

As I mentioned, our notice has a "you're done 31 days after the notice" regardless of whether they sign. A provision like that should be in the trust agreement.

That is really none of your business.

SECURE’s revision of Internal Revenue Code § 401(a)(9) distinguishes between an eligible designated beneficiary (a beneficiary who is: the decedent’s spouse, disabled, a chronically ill individual, no more than ten years younger than the decedent, or the participant’s child “who has not reached majority”) and a designated beneficiary who is not so classified. Imagine a § 401(a) plan provides that every kind of distribution is paid only as a single sum. And that a retirement distribution or death distribution is paid only as a single sum of the entire account. Assume the plan’s governing document does not otherwise require a beneficiary to take a distribution any sooner than is necessary to meet § 401(a)(9) to tax-qualify. With those provisions, is there any plan-administration purpose for which the plan’s administrator needs to know whether a beneficiary is an eligible designated beneficiary? Or must either kind of designated beneficiary get the death distribution by the end of the tenth calendar year that follows the year of the participant’s death?

Yup, it reads like 1970s badly patched computer code.

If you're asking about the 402(g) dollar limit ($19,500 for 2021) - that is an individual calendar year limit and is not affected by plan terminations, short plan years and the like.

w/o a doubt

One thing to examine is your firm's procedures regarding "EZ" plans. Our year-end correspondence always asks if the client hired any employees during the year, whether part time or full time, whether they were there at EOY or not. And who told him to stop contributing? Did he do that on his own? On the advice of his accountant? His TPA?

I agree with ESOP Guy, once you have a required beginning date, there is nothing that would allow you to stop or suspend RMDs merely because you were re-hired. Even though the RMD due 4/1/2021 was waived, it still counts as the RBD and RMDs would be required for 2021 and every year thereafter. The question becomes, is 2020 really a distribution calendar year? As CuseFan pointed out, if she terminated in 2020, it could only be a distribution calendar year if her date of birth was on or before 6/30/1949; otherwise her first distribution calendar year would be the later of when she turns 72, or retires. There is, unfortunately, no definition of "retires" in the regulations. If she was born on or before 6/30/1949 but, at the end of 2020, the employer reasonably expected her to return to work in a couple of months' time, I think you could argue that she did not retire, and therefore it would not trigger a RBD. This is not a terribly aggressive position in my opinion, but there is no official support for this stance either. If you want to play it on the safe side, have the employee take the distributions regardless.

Peter, I hope this is not a trick question. Without having given this a lot of thought, I'll say the plan, assuming it's a DC plan, just needs to (a) know there is a designated beneficiary, and (b) pay within 10 years. The only consequence of being an eligible designated beneficiary is the ability to take over life expectancy, so if the plan does not permit that, it would seem it would not be necessary information for the plan to know that a designated beneficiary is an eligible designated beneficiary.

Some of our clients have received late payment invoices, as well.

How much older than 70.5 because RMD age is now 72, remember? Her RBD, not considering re-employment, was 4/1/2021, at which point she was re-employed and did not incur a break-in-service. That re-employment is now part-time I do not think matters. I do not think that a 2020 RMD would have been due either, even if not given a legal holiday. Maybe I'm wrong or overly aggressive - but the person was employed on what MIGHT have been her RBD and is still employed, so no RMDs in my opinion.

It is 7 months after the assets are all distributed from the plan.

The 415 limit is separate for each unrelated employer.