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Would a travel trailer qualify as a principal residence?  Participant is wanting to purchase and place in a trailer park.  

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I have always checked "yes" for this question because in the case when a terminated participant takes their payout in cash taxes need to be withheld.  The letter the plan receives from the IRS assigning an EIN mentions filing a 945 which has intimidated a new plan sponsor.  I reassured them that since no payouts have occurred resulting in federal withholding, a 945 is not required to be filed.  

I guess I am just looking to be reassured myself that I am doing this correctly... Yes?

Thanks!

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CBP has fixed 6% interest crediting rate and (per pre-approved plan document selection) does NOT provide interim interest to the annuity starting date. Plan terminated, effective 12/31/2025 (also PYE) and will pay out on 6/1/2026, the ASD - there is no requirement to override the plan provision and provide interim interest (5/12 of 6%), correct?

That's true even if we had to average prior 5 years of variable ICRs, yes?

I see in the basic document the averaging requirement but nothing requiring an interim credit.

Thanks

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A religious school that gets no funding from the diocese anymore is nonetheless still qualified as a QCCO. The school was established in the 1950s, and we suspect that it would have qualified prior to the adoption of the QCCO rules. The school has been told that they likely would not qualify as a QCCO if they were to seek it out now, although they are still listed as a church related entity in the master list of catholic organizations. 

The issue arose because the school wants to adopt a 457 plan. They are considering whether to "reclassify" itself as a non-QCCO.

ERISA and tax-qualification issues for their existing plan aside, have you seen a religious school undertake this process? Any thoughts?

PS: We realize that it can still adopt a 409A plan instead, but they would prefer that distributions be eligible for rollover treatment. 

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Client received CP283 notice.  I know we can still file under DFVC Program and request abatement, my question is, has anyone done that recently and does it still generally work?  I know never say never but curious if others have done it recently.

I'm newer to the MEP/PEP space, but I'm seeing this happening constantly - wondered how common it is and what people normally do.

An adopter moves from one PEO MEP (MEP A) to another (MEP B), effective 4/1/26.  They had changed their PEO provider in November 2025 so had to make the switch.

Their new PEO provider continued employee deferral withholding during the interim move from MEP A to MEP B.  With the effective date of the adoption with MEP B not being until 4/1, these deferrals were sent MEP A to be deposited into employee accounts.  MEP A would not accept these contributions, so the PEO has just been holding on to these contributions for months.

My thought is that they would need to return the deferrals withheld between November and the effective date of the adoption into MEP B - is there any other alternative?

 

Plan has dual eligibility for deferrals and SH Match.

I understand that removes the Top Heavy 'pass' plans often get.

The Plan has like 10 participants, everyone has been there several years. Plan is 80% TH.

Are they subject to the TH minimum every year?  Or is it just for years where there is someone new and they are not eligible for the SH Match?

(We have since amended the Plan to have the same eligibility for SH as deferrals.)

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