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As a former TPA I will tell you these are generally not great clients. I dont mean in the sense that they are jerks or that they don't pay their bills. I mean they are so "unusual" from an operational perspective that only a partner can assist and answer their questions. There is no detailed work ti be done, so not much that a staff person can do. So if you bring on one of those clients, it's basically 100% partner time which starts to raise the quesiton of "can you charge enough money." I used to tell clients, "it's not worth it for you to pay me what I need to get paid to do this work for you, but I cant do it for any less. If you want me to be available to you when you call, I need a decent fee." I would review the plans all the time throughout the year for, amendments needed, invoicing, collections, you name it. Just having a plan on the books takes time even if I'm not doing any work. I used to charge $1,250 a year and I still think it wasn't enough sometimes.

I have heard of consequences from not filing a Final 5500. The two partners rolled their plan accounts to IRAs and thought that was that. Five or so years later, the IRS said your money purchase plan is still on-going. Where is your latest restatement and 5500 filing? I don't know what it cost to untangle the mess.

Okay, the idea here is that she wants to get to her DC annual additions maximum, which will likely exceed the sum of the deferral max and then the 6% DC allocation. So she does the rest as employee after-tax. as having no employees means the ACP test is passed. As for the backdoor part of the Roth, that's just a Roth conversion of some/any of the total, including the employee after-tax, so that she's basically gotten the full DC max and it's all/some become part of a Roth account within the plan.

I do not think you can formally state two groups, those employed 2/15/PY+1 and those not, because a person's grouping is not determinable by PYE. Draw a parallel to changing an HCE top-paid group election after PYE, where the result changes a person's status under the plan, which is impermissible. Using individual allocation groups in the document but in practice determining two allocation groups by your desired methodology is the best way to accomplish what they want IMHO and I think that of most others. If said 2/15 fell on a weekend or holiday and/or for whatever reason the plan sponsor wanted to accelerate or delay that date, individual groups compared to hardcoding, even if such was permissible, makes administration accommodating. Just because the document allows for flexibility doesn't mean it needs to be used. Finally, you mention a parent and a lot of subsidiaries all with their own plans with separate RKs and independent testing. Is no one concerned about testing in consideration of the control group?

This amount should just be earnings that goes into the participant's account. These lost earnings are technically interest paid on a loan the employer is considered to have taken from the participant's account during the period of time the loan payment was being held by the employer before being sent to the trust. The participant did not pay this interest, the employer did. It is considered like the employer took a separate loan from the participant's account and must pay interest on that separate loan. It is the earnings that were lost (should have been earned in the participant's account( because the payment of the loan repayment was not sent to the trust on time Accordingly, the payment of these lost earnings should not affect the amortization schedule of the original loan. Again, due to it being an untimely deposit of the loan payment, it is not an amount owed by the participant on the participant's loan but an amount owed to the participant by the employer due to its prohibited transaction loan. Make sense?