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Unless one has inside information, we don’t know exactly when the IRS will release the adjustments. But we can confidently presume the Bakers will post it on BenefitsLink promptly after the IRS’s release.

What? New "forfeitures" in a DC plan simply are internal transfers from the participant account to a plan holding account. They are not a distribution, contribution, or income. If forfeitures are used to reduce employer contributions from the forfeiture account, you would reduce contribution shown by the forfeitures reallocated.

Forgetting about the short plan year and termination for the moment, what if the PYE and valuation date was 12/1 instead of 12/31. Would your MRC due date still be 9/15 or 8/15 (8/16)? I think it's the August date. So in your situation I think it's due 7/7ish. Also, why risk a late contribution for 8 days over an interpretation question/gray area?

With this effective 1/1/24 and I think limited guidelines on how to enact this, I'm thinking that it can be administered as follows for a plan that deposits match on a payroll basis: Participant provides a recent statement of the loan showing payment amount, and amortization schedule, or length of payment plan Payroll then treats equivalent payment per payroll (loan pmt x 12 / (24 or 26) ) for standard payroll schedules. Payroll then sums up 401(k) + equivalent loan payment and applies match formula on payroll basis. Note these are just initial thoughts.

One reason some plan designers provide an involuntary distribution a little sooner than the time needed to meet § 401(a)(9)’s condition for tax-qualified treatment is that 100% of a single-sum distribution would be rollover-eligible.

While you’re helping your client consider its decision-making, consider—among many points—this question: What bad consequence would or might result if these employees become eligible to elect deferrals but are excluded from all employer-provided contributions?

Many businesses use pro re nata, as-needed, on-call, or other intermittent employees. Unless the plan’s governing document provides an involuntary distribution on the participant’s reaching a specified age, the plan’s administrator should decide whether the individual is severed from employment. A required beginning date refers, in part, to “the calendar year in which the employee retires.” I.R.C. (26 U.S.C.) § 401(a)(9)(C)(i)(II). For this context, the statute does not define “retires”. The Treasury department’s rule refers to “the calendar year in which the employee retires from employment with the employer maintaining the plan.” 26 C.F.R. § 1.401(a)(9)-2/Q&A-2(a) https://www.ecfr.gov/current/title-26/section-1.401(a)(9)-2. The rule does not define “retires”. Following the rule’s text that “retires” is “from employment with the employer”, many interpret “retires” as severance-from-employment. The Treasury department’s rule to interpret Internal Revenue Code § 401(k)(2)(B)(i)(I) states: “An employee has a severance from employment when the employee ceases to be an employee of the employer maintaining the plan.” 26 C.F.R. § 1.401(k)-1(d)(2) https://www.ecfr.gov/current/title-26/part-1/section-1.401(k)-1#p-1.401(k)-1(d)(2). In evaluating whether the individual “has a severance from employment”, the plan’s administrator might consider whether the employer removed the individual from the roster of those the employer might call for an as-needed work shift. Some administrators might look to an absence of a Form W-2/W-3 wage report for a whole calendar year as a clue to ask the employer whether it removed the individual from the roster. If the PRN is for work that requires a professional or occupational license, a nonrenewal of the individual’s license might suggest the individual no longer is available for the work.

Well, based on this sketchy information, I'd say the employer is correct. If the leave was PAID by the employer, that would be different. But it sounds like it wasn't, and an employer is not required to count unpaid FMLA hours of service for benefit accrual purposes. And don't confuse VESTING service with benefit accrual hours. Your SPD should have detailed procedures for you to appeal the Plan Administrator's decision if you wish to pursue it. Follow the procedures to the letter if you choose to appeal. Free advice is what you pay for it, so don't rely on this. You could, of course, engage ERISA counsel, but I seriously doubt the benefit, even if you were to prevail, would be worth it.

Like most open ended questions the answer is it all depends. What is the objective - rewarding/sharing in profits, retention/competitive comp & benefits package? What is the industry, how much does the person make, what can the employer afford to provide? If the employer provides other substantial benefits on the health and welfare side, maybe a SEP or SIMPLE IRA or 401(k) plan with a match is appropriate. If the employee is invaluable, say hired to run someone's business for them, then maybe a 401(k) with a substantial profit sharing is appropriate, or even a defined benefit plan if $60k-$70k in annual retirement isn't enough, although if the owner is also an "employee" then this may or may not be possible depending on circumstances. Answers to those two questions at a minimum are necessary and you ask for "best options" - for the employer or employee or blending the needs for each?

There is a lot of information here, and I am not an expert on teachers plans, but hopefully someone else will jump in. I am also assuming these are related to a defined benefit plan (monthly lifetime benefit) and not a defined contribution plan (pool of money) Teachers plans are generally operated by the state and therefore some of the QDRO rules apply differently. That said, to answer you basic question of "can a QDRO be amended post-divorce?", Yes, but it would be very rare. In order for the QDRO to exist, both parties had to agree to the current wording. Therefore, in order to change it, both parties would need to agree that the wording was now incorrect for some reason, they would need to agree to get the attorneys involved, then they would need to go back to court and get a judge to agree. So I won't say it isn't possible, but I have never seen it done. I am also not clear what you would want to change. You mention naming children as beneficiaries, but that would likely not be possible even if you could change it. QDROs can only allocate the benefit the plan was obligated to pay. Generally, pension plans only pay lifetime benefits to the employee and their spouse.

KaJay, I think both Peter and CuseFan are right on with their comments, but I would start with the above and whose name and EIN are on the W-2, if it is W-2.