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Need Information on Association Plans
Has anyone been involved in setting up an association plan for medical, dental etc?
Elimination of 401(k) match and vesting
If an employer decided to eliminate their 401(k) match, what impact does this have on vesting? Would it trigger vesting so that you would have to immediately vest everyone currently in the plan?
How about if you were to reduce the match, would that trigger vesting?
Is a receipt required for FSA reimbursements, or is a bill okay?
Is it a requirement for employees to have to submit an actual receipt of medical expenses to receive a reimbursement under a FSA, or can they submit a bill they received? In other words, do they have to have actually paid the bill, or can they receive the reimbursement before paying the bill?
HCE determination in merged 401(k) plans
As a result of a business merger, two unrelated 401(k) plans merged (plan A and L), effective 1/1/2000, with plan A surviving. The participants of plan L were eligible to participate in plan A effective on the date of merger.
For HCE determination, do I need to consider the look back year of plan L? (some owners of the employer of plan L are not owners of the sponsor of plan A).
Any help would be appreciated.
Thanks
How is ADP and other testing done (what compensation is used) when eff
If the initial plan year is the calendar year, but the deferrals were allowed starting March 1, is compensation for the full year used in testing, or is compensation from March 1 on used?
missed FICA on non-qualified deferred comp
Is there a way to reform missed FICA payments on non-qualified deferred comp. in order to take advantage of the special timing rule and non-duplication rule? The final regs' preamble refers to penalties and interest, but it is unclear whether paying these then gets me back within the special timing rule. It also seems there is a time limit on making retro. FICA payments. Thanks.
Is a graduated matching contribution plan as to tenure permissible?
Does anyone know if it is permissible for an employee to have a graduated matching contribution plan according to tenure with the company? For instance, paying 25% up to 4% for 2-5 years of service, 50% up to 4% for 5-10 years. etc. How will the nondiscrimination rules affect such a plan?
Former employer notified me of COBRA price increase 3 months late. Ca
On March 1, 2001 my former employer informed me (by email) of a 46% price increase for my COBRA health ins that was retroactive back to Jan 1, 2001. They want me to pay the increase for the past three months even though I had not been notified. Is it legal for them to do that?
403b and qualified transportation benefit
As a result of IRS sec. 415©(3)(D), if an employee has contibuted the maximum to either a 403(B) or 401k, can he/she still contibute to a salary reduction plan under the Qualified Transportation Plan ?
How many Roth IRAs can I have?
I'm new at this. Can I have more than one (1) Roth IRA???
Thanks
Can various reported income forms as a result of ROE from a Roth accou
I have received FORM 1065 (Substitute Schedule K-1), from Partner's Share of Income, Credits, Deductions, etc, as a result of ROE from ROTH IRA investment. Since Taxes are not required; do I just ignore the form?
How to handle part-timers in a plan with 3-month eligibility for parti
Lets say you have a client that is a golf course, which employs about 200 part-time staff throughout each year. They have a 3-month eligibility requirement, so most of these employees are eligible. Very few participate. The course considers them still employed on 12-31, since most will be coming back to work in the spring. Question is - what is my number of participants at the end of the year? You could make an argument that I have over 100, since there are that many that are eligible. In the whole plan, there are about 30 who make contributions. I'm looking for a way to keep the number under 100, to avoid an audit. Any thoughts?
Continuation of Coverage beyond COBRA guidelines
Has anyone been lucky enough to have their COBRA coverage extended beyond the statutory period? Or has any corporation out there been generous enough to extend coverage beyond the statutory period? COBRA does not prohibit plans from offering continuation health coverage that goes beyond the COBRA periods but I'm wondering how likely a company would continue coverage and under what circumstances. Thank you.
COBRA Violation - Delays in notification letters
A major corporation has been very lax in sending out their COBRA notification letters. This is causing insurance elibigility problems. What is the procedure for having fines levied upon this corporation by the federal government. It seems this is the only way they will take notice.
Small DB Plan Valuation Software
I am looking for recomendations regarding software to use to value small(<100 participant) defined benefit plans. Could you please give me contact information for the software provider?
I am also curious about what it costs.
Thanks
What happens with the MRD rules where a 5% owner ceases to be a 5% own
An employee is a participant in a DB plan (5% owner). The participant accepted a job with a new employer (not a 5% owner) where he will participate in a DC plan. The DB plan will be terminated. Participant turns 70 1/2 sometime this year. Can we avoid the required minimum distribution under 1.401(a)-9 by a rollover from the DB plan to the DC plan? I think the answer is no but as a result of a termination of the employer maintaining the DB plan, the employee will only be a 5% owner for a month or two of this year. Is there any rulings or regulations on a subsequent change of status from a 5% owner to a non 5% owner that might permit avoidance of the MRD rules?
Can a participant name a trust as his beneficiary?
Can a participant name a trust as his beneficiary? If not, why? If so, why isn't it done more frequently? thank you.
Terminating Simple IRA and adopting a 401(k) plan
Can an employer have a Simple IRA for 2001, decide to stop the Simple IRA during the year and then adopt a 401(k) qualified plan during 2001?
3% safe harbor with additional match
We have a safe habor plan using the 3% nonelective contribution. The plan also has a subject to vesting match of 20% all the way up to 100% of employee deferrals. I am fairly ceratin that this plan meets the ADP safe harbor, but fails the ACP safe harbor because matching contributions can occur on deferrals in excess of 6% of comp.
I have been advised that this plan meets both the ADP and ACP safe harbors. The person advising claims the match cap only applies when using the match to satisfy safe harbor.
Am I correct? If I am correct to I test on the entire match or just the portion on deferrals in excess of 6%.
Paying Certain Plan Expenses from Individual Account Plans
Can anyone expand on the rules for paying plan expenses (specifically, plan administration-related expenses) from a plan that utilizes individual accounts for all participants?
My client wants to begin charging the plan (the affected participant's account) for the fees associated with processing distributions, withdrawals & loans. (The plan document does have "broad" language that allows the trustee to pay appropriate expenses from the plan or by the Employer, so there's not a plan document issue.)
I am curious about various other threads that have mentioned a DOL Opinion Letter that apparently references a distinction between plans with pooled assets versus plans with individual participant accounts (at the trust level). Is there an issue with plans with individual accounts?
Any help would be greatly appreciated!











