austin3515

I guess it would be nice of the IRS to just tell us that logic is their position. And then what if you flip flop positions, is that ok? Can you claim 2 credits in 1 year, one based on cash basis and once based on accrual? I just think the timing of the credits needs to be explained.

Ya know I went back and red the code and it seems like it says "paid or incurred." You can interpret the word incurred in at least 2 ways as far as I can tell, so not sure, but it certainly does indicate that it might not necessarily be the same taxable year in which it was paid. I'm actually surprised I can't find anyone commenting on this question. IT seems pretty obvious that it should be addressed. That word incurred I think is too open. For example, I am doing admin for 2023, but I'm not doing the work in 2023. Was the expense incurred in 2023 or 2024? If I say it was incurred in 2023 I can take the credit in 2023. I use my fees as an example becauise it's based on the same exact rule. And what if a contribution is discretionary? Is it incurred in 2023 if a choice was made in 2024? Isn;t that different than a safe harbor nonelective built into the document where it was clearly incurred with each passing paycheck? I have no answers but I think I'm asking the right questions! I know, I know, we need guidance...

Er Contribution for 2023 funded in 2024. The tax credit is towards 2023 taxes, right?

Here is the screenshot in Relius:

I personally don't understand why you would ever not exclude keys from TH Minimum. The match is discretionary (at least in our Relius Corbel doc) so they just have to contribute 3% to get a 3% match. So I don't see what is gained.

I know in Relius there is a checkbox to exclude top-heavy minimums from testing (or maybe treat THM only as not-benefitting maybe?). I use relius ASP so it takes me 45 minutes to login, otherwise I would tell you exactly what it says, LOL,

I mean the same langauge shows up for each code so I assume this is relatively simple to program for. For me the bigger problem is the SAR will now be two pages!

I used to have a great chart of what the maximum allocation was in a cash balance plan. Rows were ages, and columns were different income levels. But the company who did that stopped doing it. Anyone know of a good website? I would figure there would be someone out there who would even have a little calculator (enter age, comp, etc and it spits out a funding range, etc). Anyway, that chart was so handy becaue you could give clients on a call a quick idea of the numbers being discussed without having to go to the actuary. Obviously you follow up with the actuary for the real numbers but again the chart was just really handy.

Seems to be back up now. Not sure if it was our end or theirs but working again.

We use Relius ASP and no one is able to use the file transfer tool to port files between the Relius Desktop and our local desktops. Anypne having the same issue? Saturday October 7th..

I had another attorney say the same thing! Great news, thanks!

Letter comes in from IRS. $150K penalty. My advice has always been: 1) Amend 5500 to check DFVC box 2) Do a DFVC filing and pay the user fee 3) Write the IRS and ask them to abate because you fully complied with DFVC. Is that what people are still doing? Firs time I've had to do this with a 150K penalty so I wanted to double check.

Maybe I am making it more complicated than it is.This is what it says the Admin Procedures section: Application to Automatic Deferral provisions to rehired Employees. Unless this Plan is a QACA, or with respect to withdrawal rights for EACAs, then rehired Employees are treated as new hires pursuant to the following (leave blank if not applicable): l. [ ] A rehired Employee is only treated as a new hire for purposes of the Automatic Deferral provisions (except as otherwise provided in the Basic Plan Document) if the rehired Employee has separated from service for at least (enter a period; e.g., 3 months) I gather what this means is if you leave for a week, a month a year or 3 years, when you come back you get re-solicited for auto enrollment. Is that where people are landing here?

We use the RElius Corbel formatted document. Anyone have any idea what the normal procedures would be for how to treat rehires? One of the options listed below should be somehow selected or known. Can it be purely administrative policy or is there an absolute answer to this question contained somewhere in the BPD? I also understand (From reading the administrative provisions and BPD) that there is less flexibility if we are trying to use the 90 day permissible w/drawal EACA provisions. Affirmative Election WAS Made 1) Do NOT auto enroll or resume any affirmative elections. 2) Subject the participant to a new auto enroll process. 3) Implement the old election on payroll. Affirmative Election NOT made: 1) Do NOT auto enroll or resume any default elections. 2) Subject the participant to a new auto enroll process. 3) Implement the old auto enrollment rate on payroll without a new set of notifications/wait periods. This option is more important of course if there is an auto escalation feature. Just curious if I'm the only who is struggling with this issue more and more as more plans add auto enrollment...

Not sure why I kept typing "Participant Employer". I guess I type the word Participant so much my fingers are on autopilot!

So much of what we do is semantics, right? LOL. Thanks!!

I've tried and failed to find out if an entity with no plan currently can adopt the Plan mid-year. Parent bought the stock recently, and are within the transition window but they want to add them mid-year, 2016-16 references amendments, but I think that's different then adding participating employers (i.e., adding a Participant Employer is not an amendment and so doing so is not covered by 2016-16). My own personal conclusion is as long as they are on by 10/1 it should be ok because they would be able to set up their own SH 401k plan in that scenario but I can't find anything at all on point.

Call me mr. practical but I'm not adding a new QNEc source to fund $50 of corrective contributions for one person. I'm just depositin to 401k. If there was some massive correction ok fine. If we were doing QNEC's to pass an ADP test, sure I would do a QNEC source,. I've always said this, whic is 100% true: IT's still a QNEC it's just deposited to the 401k source. Oh and by the way QNEC and 401k are both treated teh same for vesting, etc. I know, I know, maybe the hardship trearment is not the same. So maybe one guy might get $50 more of a hardship than he is entitled to. Is it worth all the rigamarole with forms, signatures, RK updates to the platform for $50 of QNEc to one person? Even two or 3? MAn I'll tell ya I think the answer is no.

I heard the same but I don't see how it is even possible since this is how they paid for the entire bill.

Anyone have a sample notice they have seen / prepared that they are willing to share? I assume some of the big providers have put something together...

Also just used to pull a listing of all plans effective post 12/31/2022 so that we don't file extensions for them!

I had to google it, LOL...

I have a very very very very high degree of expertise in life insurance policies. In fact I can teach anyone everything they will ever need to know about life insurance in just a few short words: Avoid life insurance in plans at all costs!!! This has been a Public Service Announcement.

Thank you, that is correct! Relius eventually sent me the PDF on how to use it. What a sweet system. I hope others get some use out of it too. To reliably identify all plans with no Roth was a huge time saver!