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pbgc time chart.pdf Attached is a great chart for PBGC termination. For non-PBGC, 15 days is for 204(h) notice - plan freeze. There is no termination notice deadline.

Looks like it is signed? https://www.cnn.com/2022/12/29/politics/joe-biden-omnibus/index.html

It is probably technically possible, or at least it is too late in the day to think of a reason that would explicitly prohibit it. That said, it seems like a lot of trouble just to delay the funding deadline of a sole prop.

Don't forget the confusion that after age 63, the catch-up goes back the regular amount - so again the education for the participants. Especially, when they complain they can't do the higher amounts they were doing.

That happens. When paid in EFTPS, the payment is to be marked for tax year 2021, even though paid in 2022. That's fine as long as it meets that particular entity's deposit deadline.

Bird, I though they made ROTH Conversions irrevocable a few years back. I agree with Cuse fan but it seem like the conversion itself is an excess IRA contribution and you would withdrawal the excess from the ROTH under the IRA procedures +/- G/L for withdrawing excess IRA contribution before the due date of the tax return.

Isn't this something the accountant should be answering, as the tax professional, rather than asking benefit plan practitioners? Unless maybe there are more knowledgeable accountants on this forum who can chime in?

I just had to laugh at this - not because david doesn't speak the truth - but rather 1) it's a "deselection game" being a recordkeeper, in that whether a plan sponsor want's a capability or not, advisors/consultants design RFPs with everything legal (and some that aren't) and if you can't check the box "yes, we can do that" you run the risk of being "deselected" and 2) we've already gotten inquiries from advisors through to our sales people asking when we will have this available..... We don't like this (Christmas Club accounts are impossible to administer in a recordkeeping shop) but we dislike catch-up Rothification even less (as do payroll providers).

I agree it is a stupid provision. I can't imagine why any small employer would want to mess with this, and we would certainly discourage them from doing so. I'd ALMOST be willing to bet that we won't have anyone who decides to implement this.

1. I hated this provision from the moment I heard about it. We shouldn't be anywhere in this mix. 2. How does Congress think an emergency savings account as part of a plan is going to be cost effective? Not sure about others, but we're not planning on giving away our time. 3. I don't know the answer, Peter, but did I mention I hate this whole idea?