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It's everything EXCEPT rollover and voluntary after-tax.

I didn't know what a "PTET" was, so I googled it. I include one of the links below if anyone is interested. I'm sure there are zillions of other links! https://www.tax.ny.gov/bus/ptet/

I would agree that 0% is less than more than 50%.

No. Under Code section 408(c)(3)(B)(i), "adjusted gross income shall be determined in the same manner as under section 219(g)(3), except that any amount included in gross income under subsection (d)(3) shall not be taken into account." Under 408(d)(3)(C), "The conversion of an individual retirement plan (other than a Roth IRA) to a Roth IRA shall be treated for purposes of this paragraph as a distribution to which this paragraph applies." Thus, a Roth conversion is not treated as part of modified adjusted gross income for purposes of the $129K income limit for contributing to a Roth IRA.

We read the new FAQs 51 as requiring that plans cover at home antigen AND antibody tests, provided they meet the statutory criteria of FFCRA 6001(a)(1) (e.g. approved by FDA or have an EUA). This is based on FAQ 42, Q4 which includes serological tests, i.e. antibody tests, in the definition of in vitro diagnostic tests. Commentary thus far focuses on the antigen test (i.e. to detect the virus) and not antibody, so just looking to see if others interpretting these FAQs to also cover at home antibody tests. Thanks.

fiddle - Lines 5a and 5b. It is part of AGI on your return. It is just excluded from modified AGI for purposes of determining your Roth contribution limit (see publication 590-A - worksheet 2.1).

I would say both antigen and antibody tests are covered per footnote 10 in FAQ Set 51. FAQ Set 51 - PDF page 3 …since June 2020, when FAQs Part 43 were issued, the FDA has authorized additional diagnostic tests for COVID-19, including tests that can be self-administered and self-read at home or elsewhere without the involvement of a health care provider, sometimes referred to as self-tests or at-home tests.10 10 The FDA provides information on which at-home tests are authorized for use at https://www.fda.gov/medical-devices/coronavirus-disease-2019-covid-19-emergency-use-authorizations-medical-devices/in-vitro-diagnostics-euas . At that webpage, the introduction lists both types of tests . There are several types of SARS-CoV-2 and COVID-19 related IVDs: Diagnostic Tests: Tests that detect parts of the SARS-CoV-2 virus and can be used to diagnose infection with the SARS-CoV-2 virus. These include molecular tests and antigen tests. Serology/Antibody and Other Adaptive Immune Response Tests: Tests that detect antibodies (for example, IgM, IgG) to the SARS-CoV-2 virus or that measure a different adaptive immune response (such as, T cell immune response) to the SARS-CoV-2 virus. These types of tests cannot be used to diagnose a current infection.

I completed the online fields, took screen shots and sent it to them. Spelled it out pretty good. I wanted them to see that I am not making anything other than my fee for services on this debacle they created. She will reach out to me if she has problems. Thanks

Probably not.

Do you need a 2848 to pay on behalf of someone? I don't think we ever got PoA.

A standardized plan probably won't allow for the DB top heavy minimum to be provided in the DC plan. If the only participants are the owners - since I really hope they're not using a standardized document if they have employees - then it probably isn't a big deal since there would be nobody eligible for a top heavy minimum anyway. Regardless I would restate the plan onto a nonstandardized document asap.

Yup. Lesser of 10% or $1MM.

If the payment is reducing income for federal income tax purposes, and it is, then I think you have to subtract it.

Just one bond covering 100% of the non-qualifying assets OR 10% of total plan assets, whichever is greater. (And, as we now remember, there is no $500,000 cap if/when the the nonqualifying assets are more than $500k. Or, I guess, $1MM if there employer securities involved.) Side question about the $1MM bond. If a plan has $12MM in assets, but only, like, $40,000 in employer stock, do I still need a $1MM bond?

Yeah, you're right. Because neither H nor W own more than 50% of corporation A, the sons' stock is not attributed to them. Was late last night when I wrote otherwise.

Well, this as it may be, the insurance company did not allow a single bond (I think it was Colonial) and had to get 2 bonds, this was a while back. I am just sharing my experience. By the way, thank you for pointing to the example.

Interesting, because that's not what the reg says. One of the examples in the reg clearly says you can use one bond to cover both the qualifying and non-qualifying assets. However it might be easier to get a second bond than to argue with a DOL agent if the plan is under audit. DOL reg 2520.104-46(b)(1)(iii)(B), relevant section highlighted.

Did you check the box "special extension and write (state)-Ida Extension-FEMA-4615-DR" So far, we have had no problem.

Full 1.5 MM.

(Send the IRS just one of the five dogs at the poker table.)

This is from 35.3405-1T, Q&A F2: f-2. Q. How is withholding accomplished if a payee receives only property other than employer securities? A. A payor or plan administrator must satisfy the obligation to withhold on distributions of property other than employer securities even if this requires selling all or part of the property and distributing the cash remaining after Federal income tax is withheld. However, the payor or plan administrator may instead permit the payee to remit to the payor or plan administrator sufficient cash to satisfy the withholding obligation. Additionally, if a distribution of property other than cash includes property that is not includible in a designated distribution, such as the distribution of U.S. Savings Bonds or an annuity contract, such property need not be sold or redeemed to meet any withholding obligation.

I agree with Mike.

Part 2 of subtitle B of title I of ERISA does not apply to “a plan which is unfunded and is maintained by an employer primarily for the purpose of providing deferred compensation for a select group of management or highly compensated employees[.]” ERISA § 201(2), unofficially compiled as 29 U.S.C. § 1051(2) http://uscode.house.gov/view.xhtml?req=(title:29%20section:1051%20edition:prelim)%20OR%20(granuleid:USC-prelim-title29-section1051)&f=treesort&edition=prelim&num=0&jumpTo=true The command: “Each pension plan shall provide for the payment of benefits in accordance with the applicable requirements of any qualified domestic relations order.” is in ERISA § 206(d)(3)(A), 29 U.S.C. § 1056(d)(3)(A) http://uscode.house.gov/view.xhtml?req=(title:29%20section:1056%20edition:prelim)%20OR%20(granuleid:USC-prelim-title29-section1056)&f=treesort&edition=prelim&num=0&jumpTo=true. So, an ERISA-governed unfunded deferred compensation plan that meets the select-group conditions need not provide anything about a domestic-relations order. ERISA does not require anything of a church plan that has not elected to be ERISA-governed. ERISA does not require anything of a governmental plan. I serve and have served as counsel for plans that do not pay or provide anything to a participant’s former spouse (or separated spouse).

RBD was 4/1/2021 and first distribution calendar year was 2020 (but RMD waived), second distribution calendar year is 2021 with 12/31 due date, that didn't change.

I believe we used to call these "excess benefit plans" and were used when participants hit a plan or regulatory limits. Haven't seen one in years, as the limits have increased to or beyond the ability of non-Top Hat group members capabilities....

IRS has released Form W-4P for 2021 Revised Form W-4P for 2022 New Form W-4R for 2022 Ascensus is reporting that the IRS has postponed required use of the two new forms until 2023 (i.e., the 2021 form an continue to be used until that time). Instructions for the 2021 W-4P do say that an election using that form will continue to be in effect until a subsequent form is submitted; I don't see anything else in any of the instructions that mentions any other delay in effective dates.

Form 5500 and 5500-SF have required, for a number of years now, an attachment when filing as a DC multiple-employer plan. For years before 2021, the attachment was required to list each participating employer in the MEP, the employer's EIN, and the percentage of the total contributions for that employer. Starting in 2021, the attachment now requires a fourth data element, which is the aggregate account balance attributable to each employer in the MEP. See the 2021 Form 5500/5500-SF instructions under Line A – Box for Multiple-Employer Plan for more information (and compare to 2020).

I would have thought EPCRS would be clearer on this, but I think the provision of 2019-19 that is applicable here is 6.07(2), which says: (2) Plan loan failures treated as deemed distributions under § 72(p). Unless correction is made in accordance with section 6.07(3) (to the extent applicable), a deemed distribution under § 72(p)(1) in connection with a failure relating to a plan loan to a participant must be reported on Form 1099-R with respect to the affected participant, and any applicable income tax withholding amount that was required to be paid in connection with the failure (see §1.72(p)-1, Q&A-15) must be paid by the employer. In this case, the deemed distribution may be reported on Form 1099-R with respect to the affected participant for the year of correction (instead of the year of the failure). I think that you have two separate things here, 401(k)athryn, i.e. the deemed distribution that occurred under the 72(p) regs in 2018 and should have been reported as 2018 income, and the plan loan offset that will occur at some point (presumably, soon) when you actually report the defaulted loan as distributed and take it off the plan's books. The way I read 6.07(2) above, although it is in EPCRS, you're not really correcting, but merely dealing with a reporting issue. Section 6.07(2) seems to be saying that if you missed it for the right year, 2018, you can report the deemed distribution in current year (i.e., 2019), but the plan would need to pay "any applicable income tax withholding" (which is probably $0). As I recall, the 72(p) regs simply provide that interest accruing after the date a loan is deemed is not taxable to the participant (either as additional deemed distributions or at the time of the loan offset), even though it continues to accrue until the date of the loan offset for purposes of blocking additional loans). The 72(p) regs also say, of course, that the loan is deemed distributed as of the end of the calendar quarter following the calendar quarter of the first missed payment (if the default is not cured). There does not seem to be a rule either in the 72(p) regs or Rev. Proc. 2019-19 that changes this result (i.e., requires the accrual of additional taxable interest) on a deemed loan that was not timely reported, from the deemed date to the date of reporting. It might make sense to keep accruing taxable interest until the date as of which you report the deemed amount, but since that is not provided for in the 72(p) regs and 2019-19 does not specifically address, seems to me at least an open issue. Just saying. Others may have different view.