austin3515

Not surprisingly (because I think FTWillilam is so awesome) they can do them all year long. The fees are very modest. I'm actually a little embarrassed I misinterpreted all of their caveats about processing deadlines at the end of January. In hindsight those deadlines obviously only related to hitting the 1/31 deadline. Thanks everyone!!

@Paul I that was the missing link for me, thank you. The red copy goes to the IRS not the participant. I get it. If FT can't do it we might work with another vendor for the one-offs, that's probably not a bad idea.

100% thats the problem. Our admin person will spend 45 minutes trying to get it to line up! I will ask FT but I thought they would not do the fulfillment piece post 1/31.

We do most of our 1099s through FT "fulfillment" service where the print/mail/ and send everything to the IRS. But after 1/31 we need to do them manually (for example when a client only tells us about it now). For years we have been ordering the IRS's red ink 1099s and trying to print the 1099s on those before mailing hard-copy to participants. Can someone explain to me why I am making my life so much more difficult even though I know from doing my own takes that taxpayers don't even send those to the IRS?? Are people sending this out just on regular whit paper?? If there was a compelling reason I would be all over it but if there is one I just can't see it...

Does anyone know how to request that the IRS abate the now 10% penalty tax on a missed RMD for 2023? I know no one knows if they will abate now that they have reduced it but I still think that the same logic of "don't stick it to an octogenarian living off of social security for a silly mistake" should still rule the day... Regardless I'm going to give it a shot but curious if anyone knows how it is done!

Thanks!! Very much so!

http://actuarialtools.com/cctable.html I've been using this site to pull the covered comp tables for years but the 2024 tables are not yet available. Anyone know where to pull them from?

From EOB, you are correct. I wasnt 100% sure if the ADP and ACP Safe Harbors had to be satisfied and the answer is yes. Now you could have a match that is 400% of the first 6% and I believe that would work. 2. Certain safe harbor 401(k) plans are deemed not to be top heavy. A safe harbor plan is deemed not to be a top heavy plan (even if the top heavy ratio, if calculated, would exceed 60%) if: (1) the plan consists solely of a safe harbor 401(k) arrangement, either under the 401(k)(12) safe harbor or, in post-2007 plan years, the QACA safe harbor, and, (2) to the extent there are matching contributions made to the plan, all of the matching contributions satisfy the ACP safe harbor prescribed by IRC §401(m)(11) or, in the case of a QACA safe harbor plan, the ACP safe harbor prescribed by IRC §401(m)(12) (which cross-references the requirements of IRC §401(m)(11)(B)). See IRC §416(g)(4)(H), as added by EGTRRA §613.

"The Employer retains the right to reduce or suspend the safe harbor nonelective contribution under the Plan. If the Employer chooses to do so, you will receive a supplemental notice explaining the reduction or suspension of the safe harbor nonelective contribution at least 30 days before the change is effective. The Employer will contribute any safe harbor nonelective contribution you have earned up to that point. At this time, the Employer has no such intention to suspend or reduce the safe harbor nonelective contribution." That's what our Corbel/Relius notice says. So it seems clear to me you can do it.

There is this thing from the IRS. IT' a good place to look and see if your fringe in question is even mentioned. The word "jury" is not found anywhere in this publication. https://www.irs.gov/publications/p15b

I've always thought of fringe as not in any way related to service (how much of it there was or how good/valuable it was). Examples of where this holds true for taxable fringes are: GTL, Opting out of benefits, Personal Use Company Car, taxable Car allowances, etc. Those items are not at all related to the value of the employee or how much they work. That's what puts them on the "fringe" I guess. Jury duty, vacation pay, sick pay, are are all paid in lieu of service so they are related to service. Now third-party-sick pay is a weirder interpretation. The benefit itself is in the form of insurance protection, via monthly premiums paid by the employer. Receiving the benefit of that insurance has nothing to do with amount or value of the service. When a benefit becomes due, the IRS requires it be reported on W-2, but that doesn't change the fact that it was a fringe at the outset (note that the benefit is paid by a 3rd party, the insurer--not the plan sponsor (edited, originally said "Client")). Anyway that's been my reliable north star.

That;s impressive. The notice we have been using is 4 pages combined, and the font looks like 8pt!

Also there is SO MUCH duplication. IT's as though they wanted to make it as impractical as possible.

I agree but we do still order thousands of copies a year and that's a lot more paper than one combined notice...

Well I was talking about the 99.999% I guess...

We send out one notice for all distributions. The admin people sure do like the simplicity of that. No edits at all. I would posit that if the only thing you're changing is the name of the plan perhaps you could skip that step with a little clever wording! That seems to be what the recordkeepers do too, but they have references to the call in numbers and websites throughout, etc.

Does anyone have a generic special tax notice that they have been using that doesn;t reference any recordkeeper names? Something special designed for TPA's for example? I know Relius Documents spits one out but I think they customize it quite a bit based on plan document elections and we want one for all plans. The IRS one has two separate notices, one for Roth and one for Pre-tax and that's, well, not workable.

The only other exception is with respect to employees who have not met the maximum eligbility provisions. So 3 months of service for 401(k) and 1 YOS for match is allowable, BUT you would lose your top-heavy exemption (if you needed it)...

You only needed one all along so it never mattered, LOL. Even the 2 year eligibility plan "never" switched to the plan year. Thanks though for the stellar response! And thankfully it lines up with how I wrote my formulas!

Would it be fair to say that "FICA Wages" = Total Compensation less Section 125 premiums? Lots of articles that throw around the term "FICA Wages" like "everyone knows what that means."

Trying to write some formulas... Plan Year End = 12/31. Participant is hired on 12/31/2023. Their first 12 months is finished 12/30/2024,which is year 1. Their 2nd year (assuming switch to plan year) is calendar 2024. Agreed? And if their hire is 1/1/2024, and their 12 months is finished 12/31/2024, because that coincides with the plan year exactly, clearly we would not count the same exact 12 months, right? I could see someone (especially a formula if one is not careful) mistakenly crediting the same 12 months twice because it counts both the first 12 months AND the first full plan year).

Trust me I think about it all the time. If I wasn't so darn busy addressing all of this stuff I just might have...

Sometimes I feel like I'm the only one who sees this. Thank you very much for saying this.

OK ya got me. but it's still got make ya mad. A rule change here and there, ok. But the stuff they're pushing is major major change... But I suppose I was indirectly implying that perhaps others of a more human-like form might throw in the towel...

People will literally quit over this stuff. I swear Empower might just shut down. How often can they spend 50 million programming for all this stuff???