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  1. IRS Notice 2024-63, Q&A E-3, permits QSLP matches to be contributed at a different frequency than elective deferral matches. Plan makes elective deferral matching contributions on a payroll period basis (that is, compensation and deferrals are measured on a payroll period basis). Plan wants to implement a QSLP match feature, making the QSLP match on an annual basis (that is, compensation and QSLPs are measured on a plan year basis). Does IRS Notice 2024-63 permit this plan design, or will the plan need to be amended to make the elective deferral match on an annual basis to sync up with the QSLP match feature (so that deferrals, QSLPs and compensation are measured on a plan year basis)? Thanks.
  2. Bruce1: I appreciate the cautionary notes. The two-year holding period is not an issue. We are responsible for the 401(k) plan and have no connection with the SIMPLE. That said, in telling the spouse she cannot roll the inherited SIMPLE into the 401(k), we will strongly recommend that she confirm with her financial advisor what the best move would be with respect to the SIMPLE. Thanks.
  3. Lou S. Thanks. I appreciate the feedback. That is exactly what I'm asking. Spouse is not a participant in the recipient 401(k) plan. She inherited husband/participant's 401(k) account and is treating that inherited account as if she was the employee/participant for RMD purposes. I understand your thoughts to be that spouse can rollover the inherited SIMPLE into her own IRA or into an inherited IRA but not into the husband/participant's 401(k) plan (where she has an inherited account but is being treated as the employee/participant for RMD purposes).
  4. 401(k) plan participant dies. Spouse is sole primary beneficiary. Based on advisor's recommendation, spouse -- pursuant to SECURE 2.0 -- elects to treat 401(k) account balance as if she was the employee. Participant also had a SIMPLE IRA. Spouse is sole primary beneficiary of the SIMPLE IRA. With spouses having full rollover rights (402(c)(9)), is there any issue with spouse rolling over the SIMPLE IRA death benefits to the 401(k) plan and having the recipient 401(k) plan treat such rollover as if she was the employee for purposes of paying RMDs to the spouse? Any help would be appreciated. Thanks.
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