austin3515

To me, just expand SCP a little more. The only high volume transaction missing is RMD's. You give me RMDs and I'll get over the rest of it. The rest of it is really really rare. And people will still correct the same way - they just won't submit the application anymore. I mean don;t get me wrong, it is shameful that they are killing VCP. I hate to say it but it sounds like a very Trumpian method of "saving taxpayers money" (i.e., consequences be damned). I guess it's hard to deny the truth of it, but these plans are such a huge part of wealth in this country that some accommodations are warranted.

Now that you mention it, I'm pretty sure someone was using that as a guideline for a minimum time frame that would be considered "substantial." But you don;t have a problem with what I laid out above?

I really like that system periodically is sending out reminder emails to this client. Definitely will need to get a demo. Following up on missing data definitely takes time and can be hard to keep up with... Reminds me of the 5500 software that sends out weekly reminders so we don;t have to. And we use Sharefile for secure file transfers but generally can;t stand it.

https://pensionpro.com/solutions/features/plansponsorlink/ Thank you Lois Baker!

Client sent me a screen shot of their prior TPA's data collection module. It seems to be called "Plan Sponsor Link". There are several tabs across the top of the screen, including one that says "Annual Data Collection". Underneath there, are a series of "Steps" including General Information, Principal information (e.g., owners and officers listings), Family relationships, Other Businesses, etc. Green Checkboxes appear for steps that are complete. It's obviously a program someone built for TPAs. And it looks awesome. Really awesome. Does anyone know the name? I figure some of you are probably using it too.

Mind. Blown.

S or C corps? That has not ever come up before. They are C-Corps though.

10 Docs own MD Practice, Inc. Those same 10 Docs own "Surgery Center Holdings, Inc." which in turn owners 60% of "The Surgery Center, Inc.". The other 40% is owned by an unrelated hospital. Each Doc owns 10% of MD Practice and Surgery Center Holdings. Here is my question. MD Practice Inc. would be the A-Org and The Surgery Center, Inc. would be the FSO. Does the A-Org Satisfy the requirement that it have an ownership interest? I presumed the answer would be yes and set out to find the justification but came up empty handed. In order for a corporation itself to be treated as owning somenthing that is owned by a shareholder, that shareholder has to own at least 50% of the corporation. So it seems to me MD Practice, Inc. is not treated as owning any part of Surgery Center Holdings, Inc. and tehrefore does not meet the requisite ownership interest. Make no mistake, my question is "What am I missing?" This has to be an ASG.

The other scenario two (presumably Facebooks) is a plan where there is a huge passing margin on the ACP test AND there are "hundrends" of HCEs so that if just one of them does a lot of after-tax it will have a muted affect on the testing. The reality is of course that for most HCE's it is likely a stretch even to do the $19,000/$26,000, so even if available only a handful would put the pedal to the metal so to speak...

And while an impeachment trial is underway! Well played, well played!

Sorry about that. Mimecast is some email protection thing we use. I reposted the link it should work now!

No need to yell at ESOP guy!

If something doesn't say it is irrevocable, then it is revocable. That's why certain legal documents include the word irrevocable in the first place. The document says it is discretionary. The document is not amended to make it mandatory merely because someone makes a decision to exercise their discretion a certain way even if that decision was made in a Board Resolution. That's how I see it anyway!

What does MEC out mean?

[edited to fix link] https://www.forbes.com/sites/davidrae/2018/09/20/rich-person-roth/#4b7ddee471fe Whenever I read "backed by life insurance" I just think used car sales man. Is this legit? I have a client who is doing this.

Fortunately for me this is a solo 401k. But contributions are discretionary so my understanding on the matter is even if declared a contribution it is not irrevocable even if participants lose out. I had a plan once many years ago where profit sharing was allocated and participant statements were distributed. Plan sponsor fell on hard times and had no money and the ERISA attorney we consulted said no problem to take it away because it is discretionary. PR nightmare notwithstanding.

Do you know if that would cover the substantial risk of forfeiture issue on a 457f? and thank you!!

Employer A deducts a $10,000 profit sharing contribution on his 2018 1120. The contribution was inadvertently never deposited, and is just being discovered now. Is there any way to "Cure" the deduction or is the only option to amend 2018 to remove the deduction and pay the new taxes?

What are the considerations regarding terminating a 457(f) Plan. I am obviously aware that we need to be concerned with presumption of a substantial risk of forfeiture. Are there guidelines? Let's say for example scenario A) is the organization voluntarily terminates the Plan; and scenario B) is the organization is actually ceasing operations (perhaps because they lost their primary grant). These are hypotheticals, but I am curious to know what the rules are concerning terminating one of these things.

There is no deferral election. The Organization is contributing an employer contribution of $10,00 a quarter in my example. The first quarter is 3/31/2020, and the last I suppose could theoretically be 12/31/2025. The question is, is substantial risk of forfeiture applied to each deposit separately (in which case the latest contriubtions seem problematic) or can it be applied to the scheme as a whole, in which case there is a clear substantial risk of forfeiture. Hopefully what I'm driving at is clear enough...

I understand that the IRS position is that amounts are not subject to a substantial risk of forfeiture if the future service is less than 2 years. So lets say all contriubtions made between 2020 and 2025 will vest on 12/31/2025. What about contributions that accrued during 2024 and 2025? I can;t find anything that addresses this precise scenario. Obviously overall there is a significant risk of forfeiture with this arrangement. But is there a significant risk with respect to the 2024 and 2025 contributions? Has the IRS ever addressed this? I think in practice this is quite common because "cliff vesting" is quite common.

The point I'm trying to make is, where is the rule itself? I have yet to see the text of the rule itself which should include effective dates, etc.

CB Zeller, this is insanely awesome... Can someone point me to the actual rules that specify this with special effective dates, etc.?

Does anyone know the answer to the question regarding anyone whose first RMD is due for the 2020 distribution year? Does that person have to take an RMD? Assume they are 5% owner and 70.5 but not 72. I assume the answer is no, but I know enough to know that the details are critical.

Thank you, I'm vesting and paying out on essentially the same day. Good point though!