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restricted purchase
I know there are prohibited transactions for IRA's but are there any on a ROTH? I would like to purchase an ajoining lot for investment.
Thanks
does 77-2 apply to end of year valuation?
If a small plan freeze is effective 7/1/05 with 204h notice handed out 6/15/05, how may this be reflected for an end of year 12/31/05 valuation? Must you use the proration method by running one val with frozen benefits and the other val run as if no freeze was made, and prorate the two costs? Are you allowed to just run the val with the frozen benefits? Are you allowed to just run the val as if no freeze was made.
Somebody referred me to rev ruling 77-2 but that starts off by saying...
Rev. Rul. 77-2
The purpose of this Revenue Ruling is to provide guidelines for determining the charges and credits to be made to the funding standard account to reflect changes in benefits that become effective after the valuation date.
....which implies to me that 77-2 only offers guidlines for changes effective AFTER the valuation date and not changes made BEFORE the vauation date.
Health FSA and USERRA Continuation Rights
As you may know, when a participant in a medical plan (including a health FSA) goes on a military leave, s/he has the right to continue coverage under USERRA for up to 24 months on a COBRA-like basis. Under COBRA, there is a special exception on the duration of COBRA coverage for health FSAs which satisfy certain rules, including that the health FSA meets a HIPAA exemption (which would usually be met if the FSA contains only employee salary reduction contributions) and depending on the balance in the FSA and the amount remaining to be contributed for the remainder of the year at the time of the qualifying event. The upshot of this exemption is that the health FSA is either not subject to COBRA continuation, only subject to COBRA continuation until the end of the calendar year of the qualifying event or also subject to COBRA for the calendar year following the calendar year of the qualifying event. I had hoped that the final USERRA regulations would provide more information on the duration of the continuation period as applied to health FSAs and whether the employer would tie that duration in to the IRS COBRA regulations. That being said, does anyone have any thoughts on how long health FSA coverage should be provided with respect to an employee going on military leave in order to comply with USERRA?
IRA 60 Rollover Rules
If you take a distribution from your IRA, and before the 60 days you deposit the funds back in, but the check bounces and you don't find out until after the 60 days are over, is there any way to correct it besides a private letter ruling?
Proposal Disclaimer
Is anyone willing to share an example of their disclaimer that they may use on a proposal/illustration of plan designs to a prospect?
5500 Codes for Line 8a
Does anyone have an opinion on whether a code value is used to denote use of a Volume Submitter Document under Line 8a of Form 5500?
Simple IRA / 401(k)
A company had a simple IRA in 2004. They closed the simple IRA and started a safe harbor 401(k) plan in 2005. They owed a contribution to the simple IRA for the 2004 year but instead of depositing the funds into the simple IRA they sent the money into the 401(k) plan and earmarked it as a safe harbor contribuiton.
We determined at a later date - 2006 when doing compliance testing on the plan that the funds should have gone to the simple IRA and not the safe harbor 401(k) plan. The simple IRA is closed and will no longer accept the deposit.
What options does the client have if any to do with the funds? Can they keep it in the 401(k) plan?
412i or Not?
Instead of paying premiums directly to the carrier, the sponsor of a 412i plan makes contributions to an investment account held in the name of the plan, from which he then disburses the premium payments. The deposits are made periodically in varying amounts, and then the appropriate premium amount is disbursed when due. The insurance guy who set this up says the account is -o- at the end of the year, so it's OK. I don't see how. Anyone agree?
Autoenrollment Implementation
For anyone out there who has implemented autoenrollment , do you have any recommedations?
Pros? Cons? Lesson learned?
What was your avergae time to roll out? thanks
Relius Gov't Forms
I know this is a Relius Admin message board...
Has anyone submitted an electronic filing (EFAST)? via modem...
The connection type that Relius Gov't forms only offeres is thru a Virtual Private Network (VPN) and the IRS is not accepting it this way until next year.
I cannot get Relius Govt Forms to recognize the previous setup I had for dialing into EFAST.
Any users with a successful submission?
Jim
Multiple Employer Plan Document
I have a client that wants to sponsor a multiple employer plan that allows each adopting employer to select various plan design options. I am having trouble finding a document vendor that sells this type of volume submitter/IDP document. Does anyone know of a vendor that sells this?
Salary for Pension Administrator
Hi! I'm working for a small Pension Company and would like to know what the average pay is? I have 4-5 years of experience. I just completed PA-1, Pa-2 and will be taking PA-3 this month. I plan to get my QKA designation so I'll be taking DC-1 and DC-2 as well. I'm having second thoughts about staying in this field because of the pay and feel that there is no room for advancement. Does anyone feel the same way? Any suggestions or feedback would be appreciated.
Timing of Amendment
In Feb 2005, a MPP was merged into a PSP. The MPP plan formula used integration and the PSP didn't. The PSP has a non-integrated discretionary formula. It's now April 2006, and the client want's to use the integrated formula for this PSP for their 2005 allocation. Can this be done?
Participant Loan Upon Plan Termination
Our loan policy nor the plan states what will happen to a participant loan upon termination of the plan. Any recommendations on what can/should be done?
Testing order
Is there a specific order that testing must be run on and catchup contributions allocated? Specifically I have a plan that will fail ADP. Owner's deferrals exceed other HCE's by about 4,500 so if I run ADP first then refunds get attributed to owner and reclassified. However, if I run 415 first then refunds get reclassified there and not included in ADP, thus plan failure gets attributed to other HCE's. So, which way do I go????
Doesn't impact owner at all, his max is his max...but since the other HCE's are children of owner it does have a dramatic impact on overall family contribution level. Children are young so are receiving 0% in profit sharing contributions so they depend on being able to maximize their deferrals.
Guidance would be much appreciated.
72(t) tax on returned excess deferrals?
Client is about to distribute excess deferrals/earnings to self-correct a 401(a)(30) violation. Because the excess deferrals are being returned after April 15, does the 72(t) early distribution tax apply to the distributions?
Control Group Transfer
Companies A, B,C, comprisee a control group and all had adopted a 401k plan. Company C is no longer under common control and wishes to establish a plan. They would like to keep all existing assets and move into the new plan without giving participants the ability to roll money out( larger assets, better pricing). Can they move the participant accounts without consent?
NUA and lump sum distributions
Can someone take only dividends as distributions from their 401(k) after they turn 55 and have separated from service without taking away their ability to do an NUA transaction on the rest of the stock? Thanks in advance for your help on this.
Child Support without a QDRO?
A state office of Child Support Enforcement sent a letter to a Profit Sharing Plan Sponsor, stating that a participant owes a duty of child support. This is not a DRO. The letter states how much is to be withheld from gross income each month for child support. It seems to focus strictly on employee income. However, an attached information notice has a small 1 sentence blurb that states that gross income includes any payment from a pension plan. The individual in question is on disability but is not receiving monthly payments from the plan. He only has about $2,000 in the plan.
I read the Notice to mean that if a participant is receiving monthly checks from the plan, it is included as a source of income, but that is not the case here. Would you agree?
Since this is not a QDRO, does that automatically mean that his plan assets cannot be touched for child support?
Finally, the participant in question has more problems than just child support. He is about to be evicted from his house and wanted to take as much as he could from the plan as a hardship. Do you think he can still do this given the child support issue?
Thanks for any replys.
Old Exams
I was wondering if anybody could point me to old DB exams (or sample exams) that students could take
to prepare for the upcoming exam. I am teaching a study class for the exam, and my students need to have some exams to practice on. Thanks for any help you can provide me.





