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austin3515

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austin3515 last won the day on March 31

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  1. Voya is actually the only one I reached out to so far 👍 Hopefully they will come through for us!
  2. Maybe you can give me the name of one of each. Perhaps they have the requisite expertise to talk to them.
  3. Tax exempt agency, created by a state statute.
  4. Trying to help an acquaintance find a cheap option for opening a 457b for a tiny quasi-government agency. Anyone have any ideas?
  5. Client received CP283 notice. I know we can still file under DFVC Program and request abatement, my question is, has anyone done that recently and does it still generally work? I know never say never but curious if others have done it recently.
  6. As we all know the IRS got rid of the "Flexible" match where you can just say the match is discretionary and come up with any formula operationally. The FT document has an option for a discretionary match (8a) where the options are "as a uniform percentage of Matched Employee Contributions" (which is of course the normal one) or "as a flat dollar amount for each Participant, which of course we don't really see. Here is my issue. I cannot find anywhere that, with respect to the "uniform percentage of Matched Employee Contributions", I am able to cap the Matched Employee Contributions at X%. So everyone has a match expressed as X% of the first Y% contributed (e.g., 50% of the first 6%). I cannot find anywhere in this document that I can include the Y% / 6% cap in my examples. Has anyone noticed this? People always say, "you can get to the same outcome if you use the maximum match section and cap the match at 3%" - that only works if you never change the match so it's not a great solution. To be honest, this was a real issue for me in the FT 401k plan as well, Cycle 3. I am very curious to know if they finaly figured this out for Cycle 4. As a sanity check I am just really hopeful other people have seen this too? Or maybe I'm missing something?
  7. You’re circumventing payroll taxes is the bigger issue than retirement plans (both are big but the IRS wants its money. Employers are less of a credit risk than individuals
  8. if they had 1099 income they should be able to do a Roth IRA. So maybe everyone gets what they want? We know clients are usually wrong when they code people as 1099-MISC employees but its not our problem. I'll bet all of our service agreements specify it's not our responsibility to make that determination.
  9. That's what I do most of the time, with all of the same explanations, but some executives still want it. I've even had business owners want themselves to be the trustees of the trust to give the program more credibility (what do they care, they were never going to take it away anyway). But for sure 8 or 9 out of 10 I am just doing corporate brokerage accounts. It's the last 2 where I figure there must be a solution. It's not that complicated.
  10. There is no lack of trust here, no one is worried about this, they just want to know what the right answer is.
  11. Truth be told this was a question from an auditor I am friends with, so I don't even know the identity! This is what I can tell you. I have been a TPA for about a million years. Partners fund their contributions at any time through the date of their 1040 due date (or partnership return if earlier) and the words "late deposit" never left my lips in those conversations. And I don't think I missed anything by not mentioning it. Tell me I'm wrong :).
  12. Anyone know of a brokerage account solution, no advisor attached, for these types of plans? I need a solution where we can have it registered to the trustee of a rabbi trust. In my experience advisors do not like working on these because the opportunity for accumulation is retty low. So I'm looking for a Fidelity/Charles Schwab type retail account where we can just fill out an application and open the account, no advisor comp. Anyone know of a solution?
  13. https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/advisory-opinions/1999-04a I saw this but I cannot figure out where the relevant part is. Anyone? Also this is the 100% owner of the business. I see the point of course about PriceWaterhouseCoopers (just to use an example that makes sense to all of us) withholding partners money and holding onto for it for 6 months... But this is definitely that.
  14. The Applicable DOL Reg: Partners ARE the employer so they have no wages. You can't withhold something from yourself. So pretty clear that they are not subject to this. My question is this: Why can't find anything that says this, like a DOL Notice or an IRS FAQ or an article by a big law firm? Does anyone have anything to point to? I know the reg is pretty clear but this can't be the first time the topic has come up as an interesting question.
  15. I mean I am pretty sure I have done this. The alternative is just not filing the one with <$250K but then you run the risk of getting the letter from the IRS looking for the missing filing. I guess option 3 is to assume "once required to file always required to file" but that hardly seems like a good option. Curious what others have done. I don't have 5500 software in my new position so not sure if its a warning or a filing error. if a filing error than obviously my suggestion would not work (unless filing a paper form).
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