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Another alternative to look at is simply to leave the money in the plan, but determine that the employee is not entitled to it. The money could then be offset against the employer's next contribution obligation. So long as there are other employees entitled to receive contributions, this would have the same financial effect as giving the money back to the employer, without the problematic issues that come up when you actually take money out of the plan.

I think you answered your own question. How many ways are they supposed to give you to fix your own mistakes?

https://www.irs.gov/forms-pubs/additional-guidance-for-substitute-and-telephonic-submissions-of-forms-w-4p-and-w-4r Whoever told you that "the IRS didn't rule on implementing" might have meant that the IRS hasn't provided any rules for implementing a simplified substitute form, like we were used to with the old W-4P. The rules for using a substitute form now are so onerous that it is basically impossible. The new forms W-4R and W-4P (or suitable substitutes) must be used starting in 2023, unless the IRS comes out with some guidance before then.

Assuming an ERISA-governed plan, this seems an illustration of another situation in which the plan’s administrator is not responsible for the participant’s failure (but might, practically, be burdened by it). David Rigby and CuseFan suggest one recognize that, even after the divorce and after the participant’s death, a court might issue a domestic-relations order. See 29 C.F.R. § 2530.206(c)(2) https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-D/part-2530/subpart-C/section-2530.206. In responding to claims (if any), a plan’s administrator should be punctilious in following ERISA § 503’s and the plan’s claims procedures.

Ms Vicki, jeans and a nice shirt will be fine. Speakers usually dress nicer and I'll always have on a bow tie. But you'll fit right in without any issues.

There is a seven day grace period, in which they automatically wave any penalty.

According to the most recent EPCRS Rev Proc, even if the plan is under Audit CAP, it is possible to self-correct. In many cases, the agent handling the Audit CAP will specifically allow you to use SCP for the self-correctable items. I see no reason why you could not self-correct merely because you submitted a VCP application. I assume that you have not yet heard from the agent assigned to review the VCP application. In that case, go full speed ahead.

There was no box - I filled that in as text in the usual spot on the form where you'd list the first PT. I've always had clients mail in the 5330 after they sign it and write their check - if you're filing a 5330 online I haven't seen those procedures.

I've done it as two pages of a spreadsheet, just label the cells to look like the pages of the actual 5330. Then fill in the actual 5330 with "see additional pages". That way, if all 52 weeks were late.....one page for the transactions and one page for the corrections.

I believe you can enter one line that basically says Late deposits for multiple pay periods in 2020 or whenever. I am not an expert on this so you may want to wait for someone else to weigh in!

Yes, you need more info, as in who owns how much of each company. There is an optional transition period for coverage and nondiscrimination that may be applied after a transaction that creates or eliminates a control group, provided certain conditions are met. The transition period includes the year of transaction and the subsequent plan year.

You can still correct through VFCP. Have lost earnings been calculated? Just a note, you cannot use the VFCP calculator to figure lost earnings unless you are submitting through VFCP. Self-correction is less expensive and less time consuming but going through VDCP protects the plan sponsor from the DOL possibly taking any enforcement action.

If found concurrently under audit, then unrelated issues would be treated at the same time under CAP. VCP and SCP are almost always handled independently, although a series of failures can become a single issue dependent upon circumstances and significance. You can also seek a PLR if the significance is in question and you cannot draw a clear distinction under SCP.