There were several new "indexed for inflation" figures for SECURE 2.0 that don't seem to be published anywhere.  I'm pretty sure these are all indexed:

1) $100,000 threshold for employer contribution credits.

2) $145,000 threshold for Roth catch-up requirement

3) Domestic Violence $10,000 limit?

Why aren't these included on any charts/tables?  Anyone have a solid source with all of them?  Ferenczy seems to have the most (hers has the Domestic Violence one, but not the employer contribution credit one.

https://ferenczylaw.com/flashpoint-2025-cost-of-living-adjustments-2-2/

Hi,

Thank you for all the insights and input. Is anyone able to post a link etc for a segment rate calculator that is based on on the 24E or 25E Table or is that not allowable on the forum? Thank you either way.

I would appreciate some guidance or recommendation for a CPA or Tax Professional. Spouse retired 7 years ago and would not execute QDRO for AP. After much litigation, court will be ordering enforcement of marital settlement agreement providing 50% of FRS Defined Benefit at the time of retirement. There’s quite a lot of retro money that will be paid. Retiree’s attorney wants to make a partial lump sum payment to lower interest prior to final judicial order to enforce QDRO. Alternate payee needs tax advice regarding pre QDRO lump sum payment and post  QDRO retroactive payments. Basic question…is a payment made prior to QDRO enforcement taxed the same as a payment post QDRO?

We have pre-approved non-standardized documents.

All defined benefit plans had to be restated for Cycle 3 by March 31, 2025.

Even though about 90 plan sponsors did adopt the restated documents by March 31, 2025, we had 4 clients who did not.

Our understanding is that the restatements can be done through self-correction as long as they are adopted within two years of March 31, 2025. In addition, we believe the plans would need to adopt all amendments between the last restatement (PPA) and now (Cycle 3) to properly do this through self-correction. This as if the plan were an individual design.

Question: Is there a list somewhere of all the required amendments between the  PPA restatement and the current Cycle 3 restatement? If so, could you let us know?

Thank you.

Hi,

North Carolina was originally given an extension until 5 /1 /2025. This included the 5500 for 2023. On 4/17/25 this extension was further extended until September 2025. This additional extension from 5/1 /2025 to 9/2025 includes the 5500 and the pbgc filings. Correct? Thank you.

Husband has owner-only K and DB plans.  Spouse has her own owner-only K plan with a bundled provider for a couple years.  

Total assets exceed $250,000 so all plans are to file 5500s.  We are investigating if 5500 has been filed for her k plan.  I doubt that the bundled provider inquired as to whether she was part of a controlled group.

I don't know how far back her plan goes. She was added for coverage under his DB plan for a nominal benefit which I was told was required due to being a controlled group - maybe 401(a)(26).  That may have been the first year of her K plan.  I realize the max penalty is $1500 but hopefully someone doesn't have to go back a bunch of years to file.  I have a feeling we'd be asked to do that even though we have no role with the plan.  You know how things go - the record keeper will say they are investment platform only.

Thank you for any comments.

Tom

An association of related businesses sponsor a closed MEP. There is one Form 5500 filing that includes the Schedule MEP. I'm not able to find clear guidance on how to file a Form 5330 in a closed MEP situation. Let's say there are several businesses in the MEP that fail to distribute ADP failures timely. Does only 1 Form 5330 get filed with the aggregate of the prohibited amount reported for the excise tax? What about late deposits? 

Hello,

When I submitted my 2021-2023 renewal, I included many live and on-demand ASPPA webinars in my CEC counts, as I normally do (I don't normally pay attention to my PTIN record as I didn't think they normally rely on that). The IRS emailed me saying I was short a bunch of credits (all that weren't on my PTIN record), and that I had to submit the "IRS program numbers" for the courses in order to receive credit.

Upon requesting the program #s from ASPPA, I learned that none of their webinars that originally aired in 2021 (whether viewed then or on-demand in 2022) were eligible for ERPA credit. It appears that at least some of them had program #s at some point, and it seems like they were intended to qualify but something failed in the process (perhaps related to COVID?). Now I'm short a bunch of credits. I'm not able to find whether ASPPA originally communicated whether ERPA credit was available for each webinar, but I normally confirm that when I sign up.

Obviously, we need to monitor our PTIN records closely real-time.

Has this happened to anyone else? Were you able to resolve it with the IRS?

Let's say an employee enrolls in an HDHP with family coverage and contributes to an HSA. Their spouse contributes to a general purpose health FSA, which we know is disqualifying coverage for purposes of the HSA. But how would the IRS know this? It doesn't seem that health FSAs are reported to the IRS (whereas dependent care benefits, like dependent care FSA contributions, are reported on W-2). What am I missing? 

Can anyone provide a code citation that defines when a participant in a defined benefit plan (CB in this case) is considered to have been paid a lump sum distribution? Date funds leave the trust, or date participant has control of the funds? Or something else? I've looked, but I'm not a very good looker, and hoping someone here can at least point me in the right direction. Even if no citation, would love some opinions on this. 

This is related to some mandatory cash-outs that were started the last week of Dec 2023 from a calendar-year CB plan. The Plan wired the required funds to the distribution custodian on 12/26/2023 and provided participant hypothetical balances as of 12/31/2022 (Plan Doc does not allow pro-rata interest thru ASD, just the last-day interest credit). TPA states that since funds were sent to distribution custodian before 12/31/2023, the participants are considered paid in full as of that date.

We've since learned that several of the participants did not receive funds until well into February 2024 (delays in responses, paperwork, etc.). Anyone feel like they were shorted their 12/31/2023 interest credit?

Thanks in advance!

Hello,

I was wondering if it is unlawful for a company to deny opt out money that they offer to all eligible employees to married couples that both work for the company? As individual employees we each receive a benefit plan that includes Healthcare. We choose one family plan through the wife's benefit package, therefore not using the husband's benefit package. Yet, we are denied the opt out insurance money for not using the husband's Healthcare plan. Could this be considered discrimination based on marital status?

Thank you in advance!

We have a participant who died, his wife beneficiary was injured in the car accident as well and has medical bills so she is in a big hurry to get his account which is $100,000+.  (So the plan sponsor puts the medical bill guilt on us.)

We asked for the death certificate but was told it would not be available for 12 weeks.  The record keeping platform does not require a copy.  

I see 2 options:

- Ask the plan sponsor owner to confirm that the participant died and then we rely on his direction (such as did you go to the wake and see the deceased?)

- or wait it out and require the death certificate.  I'm strongly inclined to require this. I don't want to take any chances.

Comments?

Thank you, Tom

Company is looking to terminate their SIMPLE IRA ASAP and replace with a Safe Harbor 4% match 401k in 2025. Soonest possible would be 6/1/2025 after giving the 30 day notice for Simple Termination. Would the effective date of the 401k be 6/2/2025? Or would the effective date of the 401k Plan be 1/1/2025 with a special start date for deferrals as of 6/2/2025? I would assume the plan would begin 6/2/2025, but I know Safe Harbor Plans should be in place for the full year. Is that not a requirement if doing a mid-year simple replacement? 

The Smple Plan is set up for a 3% match. Would that be pro-rated the same as the Safe Harbor Match? Ie,a 3% Simple IRA match for half the year + 50% of the SH match for half the year would be an effective match of 3.5% on 4% deferred for 2025?

Also, he says he notified employees via email in December of 2024 that the Simple IRA was terminating. No deferrals/contributions have been made in 2025. Would that notice work? Or does it need to include language regarding the replacement with the SH 401k?

Employer is approaching 100 employees.  Only 4 participate in the current SIMPLE plan.  They are eligible but don't participate and most don't speak English.  It is an egg farm.  You do wonder if they know they are eligible.  Most employees hold a permanent resident card but that expires in the next couple years.   

I see the IRS 100 employee prior year rule with wages of at least $5,000.  I don't think any type employee can be excluded from this count.  It's simply $5,000 or more.  I don't know that a 401(k) would be worth the trouble with auto-enrollment, etc.  The new plan would like to be referred to us which I'm not sure I would even want!

Comments?  I doubt classes of employees can be excluded from a Simple IRA count.

Tom

An employer sold to a new entity and shut down their business checking account prior to payment of final employer SHNE and PS contributions.  TPA was notified last month and has the plan terminating in 60 days.

I am not aware of how an employer contribution would be funded by anything other than the business account.  They want to use their personal account, but I am fairly certain this is not an option.  Any advice for remittance of the funds?

Thank You 

Is a plan amendment required prior to 1/1/2026, or does this just fall under the general SECURE/2.0 amendment deadlines - in other words, it can be handled operationally as long as amended by the deadline? Recognizing, of course, that notification will need to be given to the HPI's as well as participants who will now have a Roth option if they didn't have it before, etc...

Bleah.

Deferrals/SH: age 21, 2 months, quarterly entry

PSC: age 21, 1 YOS, Immediate entry

both SH and PSC exclude pre-entry compensation

if an employee who became eligible for def/SH on 7/1/2024 with a pre-entry compensation. since he is entitled to SH, then he needs to get GW min. we use 5% GW test method which allows us exclude pre-entry compensation. can I use the SH post entry compensation for GW min calculation in this case? or we have to use full year compensation for GW since the post entry comp is for SH but not PSC?

thanks in advance

Plan is a 401k PSP pooled account. The trustee and her spoiuse both took out 2 loans a piece and defaulted on both of them. One in 2022 and one in 2023. Their CPA issued the appropriate 1099s.  There is a zero balance showing for their loans.  They want to pay the balances off. Can they do that?  Plan doc says the following:   TYIA! 

There must be some website where I can download the APRs for cross-testing, right?  There should be tables for each mortality table and different interest rates. I know I can export them one at a time out of Relius but I am assuming some website has them somewhere?

Hi all,

I'd love to hear your opinions on this, because I've had a bear of time trying to find an explicit citation that addresses my thoughts one way or the other.

I have a 401(k) Plan with the following eligibility conditions: deferrals & SHNE, Age 21 & 6 months, immediate entry upon eligibility, profit sharing, Age 21 & 1 Year of Service, entry 1/1 & 7/1.

The Plan document reads "For allocation purposes of the 5% Gateway Contribution described under (A) of subsection (iii) above, 415 Compensation shall be determined for the Plan Year (rather than the Limitation Year) but shall exclude 415 Compensation paid while an Employee is not a Participant in the Plan." (It's a Relius document.)

I have 3 individuals who were participants in the deferral and SHNE components of the Plan for the entire year, but entered the PS component on 7/1, so they have partial year excludable comp for a particular Plan component, but they've received 401(a) contributions the entire year. Is their 5% gateway test compensation based on their post-PS entry compensation or their full year comp?

An additional question boils down to is compensation paid prior to participation in a certain component of the Plan a 414(s) safe harbor exclusion or is it only compensation paid prior to overall Plan participation? Does it matter if two different components which are both 401(a) contributions have different pre-participation compensation amounts?

Even more simple question, can someone point me to where pre-participation comp as a 414(s) safe harbor exclusion originates? I've found lots of articles saying so, but I seem to be reading past the primary source language listing this.