Leaderboard

I think LTPTE determination starts on the employee's date of hire or 1/1/21, whichever is later. Kind of like plan eligibility: if you work a YOS (or whatever) before the plan starts, then you are eligible for the plan on the first day of the plan (ignoring amnesty dates and such).

uggh my bad. I think you are referring to my lack of consistency. It seems to be either 60 or 90 with the clients who are using this convention (or 30 of course). In paragraph e. (which is ____months of elapsed time) we enter the following exactly: “90 days of service –approximately 3 (three)” Then the SPD and the AA both say “90 days of service – approximately 3 (three) months of service” and the failsafe eligibility language won’t display.

And do so yesterday.

Generally applicable across the board, getting affirmative elections is better than using default elections.

Probably "60 days of service..." instead of "90 days of service..." would work better. 😇

I think I have a best possible solution. Not perfect, but ok and certainly better than what I'm getting today. In paragraph e. (which is ____months of elapsed time) we enter the following exactly: “90 days of service –approximately 2 (two)” Then the SPD and the AA both say “60 days of service – approximately 2 (two) months of service” and the failsafe eligibility language won’t display. I think that will work... Like I said not perfect, but good enough.

Actually, I believe no tax on tips only applies to federal income tax, tips are still reportable and subject to FICA and FICA Med taxes. So, you need to be careful about how you define covered compensation, and, careful about your payroll processing as well.

defer to legal counsel

If you maintain separate plans going forward I think you can get away with it as long as you don't have a pattern of regularly adding new plans to re start vesting schedules as that would be a pattern showing abuse. Once you merge one plan into the other though in a single employer, you can't exclude those years anymore.