Leaderboard

Maybe, maybe not. Some of the "drawbacks" may or may not include - Required Contributions. PBGC Premiums Buying annuities for participants who elect them given the low interest rate environment Potentially higher top-heavy benefits Guaranteed interest credits in a time of extended market declines Satisfying §401(a)(26)

seconded

What we really need is to push to eliminate the 5558 all together and just make the deadline for 5500's and SSA's 10/15 (or the equivalent for off-calendar).

I think you can do the 2022 calendar year plan year effective 1/1/2022 with employer contributions only. As a nongovernmental 457, this is an unfunded NQDC arrangement. Assets can be set aside or deposited to a rabbi trust, or they can simply be bookkeeping entries. If they are immediately vested, I also think contributions are subject to FICA and Medicare taxes.

Next time draft it to say the plans are merged as of the stated date and the trustees shall transfer the assets as soon as administratively feasible. That's what we always do. Very important to keep it general, especially if the merger involves liquidation and reinvestment of cash.

Belgarath, I will assume that by "one person LLC" you mean the tax-exempt org owns all of the interests in these LLCs. Assuming that, under Treas. Reg. 301.7701-2(a)the LLCs are treated the same as a division of the tax-exempt org for income tax purposes. 457(b) is an income tax section. None of that is common sense, but based on it I would go with your common sense. Get the LLCs to sign up all the paperwork, however, since that is not entirely a Federal income tax issue.

Roger that!

If the plan allows expenses to be paid from assets and a recent invoice that could have been paid from the plan was instead paid by the plan sponsor, the plan sponsor can submit that invoice to the plan for reimbursement.

Tell them how much you'll charge to allocate and distribute a handful of pennies.

I would NOT pay money to the sponsor. Bill them for miscellaneous work, like researching the problem and have the plan pay you. Alternative is to cut everyone a $.50 check and bill 3X whatever the amount is for calculating and processing them.

Agreed