Bruce1

I'm not sure using the oldest son's date of birth would be correct because a portion of the fathers money would be son A and the other portion of the money would be son B. Each son would have their own lifetime factor. It's a minimum distribution so there's no penalty for overcalculating or taking more.

Yes she would be able to transfer into her name and defer the tax implications of RMDs.

Which IRA custodian does everyone use for force out IRA's?

I'm not sure why the IRA custodian is wanting to return the money. I'm sure they can do a deposit correction and have the money journaled to the correct account. It seems like there would be an issue rolling money back into the plan because she is no longer a participant.

Just briefly reading over your post, why don't you have the employer fund the contribution after the plan year? Just do one big contribution?

I thought so...

Would it be an acceptable practice for the employer to go to employees and have them sign a deferral election form retroactively stating whether they wanted to make deferrals off of bonuses? The employer could then make corrective contributions to employees who genuinely wanted deferrals coming out of their bonus pay?

I have an employer from a small company who didn't withhold any 401k deferral and match for a large bonus paid to employees. Employees missed out on a few thousand dollars in match, as well as deferral. Question: 1. Can an employer go off a verbal consent to not withhold money from this pay? (Their deferral forms don't have an election for bonuses, thus all pay would include an ee's deferral election) Solution: 1. A 50% QNEC for missed deferral (plus earnings), and a 100% QMAC based on missed deferral (plus earnings)?

Do you even have to file the first year?

Don't additional contributions get swept based on previous withdrawal instructions?

@Jakyasar A few points to go over: 1. If a non-spouse inherited an IRA they generally start an inherited IRA (for tax deferral purposes). They will "generally" have to take RMDs from the inherited IRA depending on circumstances. 2. If the individual who inherits the IRA, decides to cash the IRA into their bank or another non-IRA account it's no longer an IRA and it's considered after-tax money. 3. From what I briefly read online you cannot do a Roth conversion from an inherited IRA to a Roth IRA. I think the reason is that the non-spouses bene cannot assume the inherited IRA as their own. If you were able to convert the money into Roth, then the tax deferral could essentially go on forever.

The top-heavy minimum contribution will look at the highest key employee allocation rate that takes into account all contributions of that individual. Whether it is considered employee or employer doesn't matter because the min takes into account everything.

Have you considered a top-paid group? Or are most of the HCE greater than 5% owners?

The regulations are written in a way to protect the benefits of NHCE compared to the benefits of an HCE/Key. But do the regulations have parameters around the amount of benefits provided between the HCE group, or the NHCE employees? For a new comp allocation could an employer at its discretion for example provide a larger benefit to a single NHCE, or even no benefits to a certain HCE? While still passing gateway etc. I'm curious is there any regulatory language that prohibits an employer from discriminating within HCEs or NHCE?

https://stwserve.com/new-irs-regulations-on-year-of-death-rmds/ The IRS just released final regulations on this issue. Above is the article that addresses it. One individual could take the full required RMD for the original IRA owner. There are some issues, what if the individual who was supposed to take the full required RMD doesn't take their RMD? What if the children don't talk to each other? In my opinion, it would be safe for each IRA beneficiary to take their share or portion of the RMD. There's no penalty for taking amounts above and beyond the RMD for a beneficiary.

When calling the IRS number, they didn't let us get the plan's EIN without the plan sponsor on the phone. 401(k)s are tax-deferred. I've never a 1099 INT or DIV from an IRA or 401k.

I assume that when an employee makes repayments on their 401k loan, the employer doesn't match those repayments because it's not a contribution. I haven't seen anywhere that an employer couldn't match those repayments, but my gut feeling tells me an employer doesn't and shouldn't match 401(k) loan repayments.

Morning star or we use firm plus. Every investment/mutual fund will have a fact sheet and prospectus. Record keepers can have hundreds of investment options, so they can feel free to read through them if they like lol! Information on investments are generally readily available. I've seen 3(38)'s at 10 bps. Good luck!

Gadget we're likely taking this plan to a recordkeeper for this reason. The investment management subsides our administration. We've eliminated the option for hardship distributions, loans, and in-service distributions . The plan document makes terminated employees wait until after year end and after all contributions go into the account. It makes calculating their money types easier. Not really.

Our firm is managing the investments and the administration for a client where each participant has individual brokerage accounts. We process def, match, and ps into each of their individual brokerage accounts. For those who have client's that aren't at traditional record keepers, is it recommended to have individual accounts for each money source?

We have a signed deferral election form to cover our bases.

Do you have a link so I can do more research on the triple-stack match? @Artie M I'll look into how we can declare the discretionary match. I assume that since the match is discretionary, we can declare and fund the match after the year-end.

The plan provides a safe harbor match, matching 100% of compensation up to 6%. I was referring to if we added a discretionary match, matching 100% of compensation up to 4%. From my understanding, you can't provide a match on deferrals that exceeds 6% of comp and pass the ACP test. From what I read, I can't do a discretionary match exceeding 4%? Meaning I can't do a discretionary match of 200% on the first 4% of compensation?

The plan has 3 employees. The owner and his spouse max their 402g and then an additional employee NHCE who doesn't contribute. The plan is a safe harbor 6% match. Since the NHCE employee didn't contribute for 2024. Can we declare a 4% discretionary match for the 2024 year and will the match have to be run through the ACP test? Is there anything I'm missing here?

You could request a deposit correction?