With Revenue Procedure 2026-4, the user fee for a Voluntary Compliance Program submission after January 29 is $4,000. See page 245 https://www.irs.gov/pub/irs-irbs/irb26-01.pdf.

How much does the IRS user-fee amount (not the practitioner’s or service provider’s fee) affect your client’s evaluation of whether to do a VCP submission?

Participant is due $1.80 in earnings due to a late deposit of a loan payment.

How do I process that in Relius?  

Do I just do a Loan Payment for the participant and only allocate $1.80 in interest?  Will that mess up the amortization schedule?

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We have a small law firm that is being sold to a larger firm.  The small firms has a calendar year 3% safe harbor 401k Plan.  Lets say the sale date is April 1st, about 85 days away.

(1) can the plan set a termination date before April 1st?

(2) If we can set that date earlier, (say March 1st) the 3% safe harbor contributions can stop as of Match 1st, even though individuals are on payroll through April 1st?

Thank you

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Business owner has a spouse that has FICA less than the $150K threshold.  It is my understanding that the spouse would not be considered a Highly Paid Individual for Roth catch up rules.  Do you agree?

A participating employer in my client's 401(k) plan is being purchased in less than a month, and the agreement says they must be removed as a participating employer of the 401(k) plan and the employees must be removed from the plan as of the transaction date. The employees are to be moved to another plan, but it is not feasible for the recordkeeper to set up a new plan until at least March 1st. 

Any ideas on how to make sure the agreement is followed with this administrative restriction?

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I have a client with 120 employees (All Full-time) who is currently ACA-compliant with their offer of coverage. They are creating a new entity with only one employee (Full-Time), but with identical ownership to the existing business, so this new entity will be considered an ALE Member within the same controlled group. I’m trying to confirm what their ACA penalty exposure would be if they decide not to offer benefits under this new entity.

For Penalty A, my understanding is that the new entity would be exempt due to the allocated reduction of 30 full-time employees. The allocation for the new entity’s share of the 30-employee reduction would be:
(1 / 121) × 30 = 0.24. Based on the guidance below, this would round up to 1, and since the new entity has only 1 employee, Penalty A wouldn’t apply?

“If an applicable large employer member's total allocation is not a whole number, the allocation is rounded to the next highest whole number. This rounding rule may result in the aggregate reduction for the entire controlled group exceeding 30.”

My next question is, Would Penalty B also not apply since no offer of coverage is made ? It appears that a requirement for penalty B to apply is an offer of coverage:

an applicable large employer offers to its full-time employees (and their dependents) the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan (as defined in section 5000A(f)(2)) for any month, and 1 or more full-time employees of the applicable large employer has been certified to the employer under section 1411 of the Patient Protection and Affordable Care Act as having enrolled for such month in a qualified health plan with respect to which an applicable premium tax credit or cost-sharing reduction is allowed or paid with respect to the employee,

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Hi

A Happy New Year to All. Is there anywhere on line that one can download a fillable pdf of a schedule SB? Thank you!

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