Leaderboard

I've never seen this before either. Was the form perhaps filed late? And this is for late filing penalties? Or incomplete (i.e., missing schedules or attachments that relate back to IRS (as opposed to DOL) portions of the form)? How would IRS even know what to "change" on an "information" return? I would contact the phone number on the notice and ask what's up.

If a retirement plan’s circumstances include the trust’s investment in an employer security or a significant stake in a security beyond pooled investment fund shares, some TPAs drop a courtesy hint or reminder. Some might do this quietly with the plan fiduciary’s lawyer, if the TPA has a working relationship with that lawyer. Otherwise, a TPA might suggest to the plan’s fiduciary that it ask its lawyer. While many TPAs gives tons of legal advice (and on some topics know much more than many lawyers), the Corporate Transparency Act might be better suited for a handoff.

Well the first thing regarding that - The plan documents probably indicate how the THMs are allocated in either, both, or (perhaps likely) just the DC plan. If the DC plan document says all the non-keys get 5%, then they get that regardless if TH could have already been covered. The rate of accrual in the CB plan doesn't matter as much, like how DC plans can sneak by with a lower THM rate if no Key gets to 3%.

If the transfer-to-PEP paperwork mentioned transfer of *all* assets/liabilities of the prior plan, that should sweep up the receivable as well, no?