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Adding to the chaos, DC Cycle 4 technically has started already but the IRS is not yet open for business to receive submissions. The IRS expected to open the submission window from Feb. 1, 2024, through Jan. 31, 2025, but I have not seen an announcement. If the window is open soon, we likely will be doing Cycle 4 amendments for everyone with the restatement period running from the latter part of 2026 into 2028. The December 31, 2026 hits right around the beginning of that restatement period. The LRMs were updated this January and are available here https://www.irs.gov/pub/irs-tege/dc-lrm0124.pdf if anyone has time to spare to read through 149 pages. If the submission window does open soon, imagine how much guidance has yet to be issued that will not be in the LRMs included in the Cycle 4 documents.

The amendment date should be after the date the practitioner is planning to retire.😁 (If there is anyone reading this who doesn't have a sense of humor, please ignore the above comment) But seriously, to a certain extent the amendment date may also be driven by other factors - staffing, number of plans, other projects such as restatements, etc.

Remember that IRS Notice 2024-02 extended this to 12/31/2026.

Yes, Nationwide went to a new platform in mid-Jan. this year. Yes, it's been a challenge. But no it shouldn't take weeks. Days maybe. The employee should check with NW for a status. Not much you can do about the market though.

The plan document will outline when a rehire re-enters the plan. That’s the cite.

RMDs for Beneficiary traditional IRAs can be aggregated , if inherited from the same decedent (original owner). Like the RMD rules for owner IRAs, the RMDs must be calculated separately, but the total can be taken from one or more of the multiple beneficiary IRAs.

They were an employee for those month, so if they met the eligibility conditions they would be in the test. Compensation would be defined in the plan document but I'm guessing that yes the W-2 wages would be used. And they would probably be treated as terminated as an employee since they are now an IC but you can confirm that with the client.

yes We haven't filed for many, many years. If you have a pre-approved document, and keep it up to date, then there should be no problem with the language. And getting an FDL does not protect you from being audited on the plan's operation. IMO, they have raised the fees to a point where they are essentially saying "don't bother us."

In general, no notice is required for a 401(k) plan termination. The notice you are asking about only applies because you are seeking a determination on the termination. The instructions for Form 5310, line 19 states Following the reference to 1.7476-1(a)(i) And on to 1.7476-2(b) 601.201(o)(3) is a very long section, but the timing rule you are looking for is in subsection (xv) Presumably, the notice has to be given to interested parties before the application is filed, so that an interested party has the opportunity to raise a complaint with IRS during the determination process if they feel that IRS ought to find against the plan.