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Yes, this is normal. The number that they need is the EIN of the trust, not the EIN of the employer.

I've always wondered about this. In the upper-right box under the YEAR, the form clearly says the for is open to public inspection. Maybe not on the EFAST website, but I would think that it can be obtained from the DOL Public Disclosure Room.

Typically owner-only plans make up 10-20% of the TPA book, with multiple owner entities comprising about 20% of them, usually partnerships or a successors arrangement with a younger minority arrangement. Almost all will have a financial advisor involved; but usually SDBA accounts with each owner engaging his own advisor. Biggest issue is lack of formal Plan Document, too many brokerages make it seem like their account application will cover the doc requirements in these arrangements. As a TPA, my focus is on providing services centered around ERISA and related IRS/DOL regulations; state law is only considered specific to particular divorce and maybe probate benefit situations when invoked. Even where ERISA may not apply, I'll lean on those precepts for guidance and shape my communication accordingly.

You've got a single 415 limit between the 403(b) and the k plan if the Dr. "controls" the "practice" he is starting. 1.415(f)-1(f)(2), as you have already discovered in your research, AlbanyConsultant. Splitting a nonexistent hair, AlbanyConsultant. See 1.415(a)-1(b)(3). Basic rule of Federal income tax: "Read, and keep reading."

Well if 1 is the only problem. You over contributed for one participant for 2020 but deposited in 2021. Shift the $2K excess from 2020 to 2021 and have them file amended tax return for 2020 with lower deduction. If you have an excess for them for 2021 - move it to someone else along with earnings. If owner was supposed to get 5K for 2020 but got $0, shift the 2K to him and make the additional 3K due. You have an excise tax for the 2020 plan year for failure to meet minimum funding by 9/15/2021 and probably need amended 5500 return for 2020 to report the failure to meet minimum funding. If 5330 excise tax is late, pay the penalty (not you but client). You are in the 2 year window so I think this can be self corrected under EPCRS if you meet the rest of the criteria in the rev proc. but double check that this isn't something that requires VCP.

It is the volatile market problem. I used to do nothing but pooled balance forward plans. Back in 2008 we had a hospital that had to amend their plan that allowed for in-service distributions based on the last annual valuation. A doctor figured out in Oct 2008 he could get his Dec 2007 balance by asking for an in service distribution. He told his fellow doctors and started a run on the bank. It was going to stick the people who didn't take a payment in 2008 with all of the 2008 losses. That is not a good/fair way to run a plan. The plan was changed to you can get 70% of the last valuation balance with a true up after the next valuation. They even hired us to do quarterly valuation updates.

The IRS position on this is crystal clear. They regard it as a violation of Code Section 410 (a) which permits a maximum eligibility condition due to plan eligibility of one year. There are a lot IRS Revenue Rulings from the 1970s and 1980s clariifyng how this rule works.

If the intention of the plan sponsor is to have the employees of the Q-Sub participate in the plan, and if the plan document does not provide that all affiliated employers are deemed to have adopted the plan (i.e., it requires members of a controlled group, etc. to explicitly adopt the plan) then have the Q-Sub explicitly adopt the plan. It can't hurt and it can only help. If they don't want the employees of the Q-Sub to participate, then add them as an excluded class of employees in the plan document. Maybe it's not strictly necessary, but again it can't hurt and it can only help.

Certainly not definitive, but at least one major TPA lists this as an eligible FSA expense: https://www.payflex.com/en/employers-brokers/products-programs-health-care-fsa.html