austin3515

I feel the same way about my checklist as Coca Cola does about their recipe! It is THE secret ingredient!!

Looking forward to Larry Starr's rebuttal

So Tom, you are saying you think it would be in then? I suppose that is California's interpretation but they've got nothing on you for Pension Expertise! It seems to me the reference to hotels would be exclusive of the deceased?? I can;t tell which side you are falling on. So to clarify, you think my participant might have a legitimate expense here??

We leave no stone unturned when it comes to our participants

(5) Payments for burial or funeral expenses for the employee's deceased parent, spouse, children or dependents (as defined in section 152, and, for taxable years beginning on or after January 1, 2005, without regard to section 152(d)(1)(B)); or Participant's father passed away. Participant lives in California, and father lives in Delaware. Participant is coordinating the "particulars" of the funeral. Would his air fare/hotel expenses count as funeral expenses? What about his sister who is also coming to the funeral, who might be helping out while she is there?

The code Q for the IRA is what it makes it so galling... I wonder if they said "well there are more IRA distributions than 401ks so we'll use the the Q for those. But now we have no other appropriate letter for the same kind of distribution from a 401k so let's just not address it."

Nope! It's the one obvious example they chose not to include...

Lou S, you mis-understood, I meant something in English! For example, if you can find the explanation for precsieliy how to complete a 1099-R for a qualified distribution I'll be thrilled. What codes? Taxable amount 0? Do I fill in first year/cumulative Roth? The list goes on!!

Yeah that will work! And another thing--When do I need to add the cumulative contributions and first year of contributions. I think it's different depending on rollover not rollover, qualified vs not qualified. I think this could be really quite the table...

Can anyone point me to a good write-up of what codes to use for Roth distributions. There are dozens of combinations and permutations (maybe I exaggerate). Qualified/nonqualified, rollover/non-rollover, Code 1,2,7 etc. For example I cannot find even in the instructions how to report a non-rollover qualified distribution. The instructions just don't say what to do. What I need is a chart that goes through the scenarios and I can pick the codes. Maybe I'm overthinking it and someone can set me straight

Me too!

But this is not an owner-only plan - you need to file a regular public 5500-SF. Not sure if that has been said clearly above, but maybe I missed something.

Ummm... You need to involve Fidelity. They handle everything. And I hope you give them 3 months of lead time! If you do it without them, you will end up regretting it I think. Work within the system, it's the only way that platform works. I learned that the hard way. The words "flexible" and "accommodating" do NOT rush into mind when thinking of how to describe them.

My advice for small loans will clearly be to pay the taxes for the participant, and your outa luck in terms of future tax deferrals.

http://ferenczylaw.com/flashpoint-sticking-it-to-the-little-man-why-the-new-irs-vcp-fees-are-bad-for-small-business-tpas-and-retirement-plans/ An even better one from Ilene Ferenczy. Very good 30,000 foot take on the industry's relationship with the IRS. A MUST read. Really very enlightening.

http://www.relius.net/News/TechnicalUpdateDetails.aspx?T=P&1=1&ID=1115 Nice write up by Relius.

NAPA will by my heroes if they can fix this. ASPPA, now that the tax law thing is said and done you should reorganize your efforts to bring this back!! If anyone is listening of course! This is just real bad policy.

Our document provider pretty much came to the same conclusion. If they moved to custodial acccounts, no hardships, etc. He wanted to say that we should be ablet o track the money that accumulated in the annuity under a separate accounting but he thought even that was tough to rationalize based on the language in the regs.

Exactly.

That is such a dirty trick. Sadly what it means is no one will file for these anymore. For loan defaults, the participant will just have to be out of luck. Maybe if the participant is lucky, the employer will pay their taxes. And RMD people, wll, the participant will be stuck paying the excise tax in some situations. Nicely played.

https://www.erisapracticecenter.com/2018/01/annual-irs-revenue-procedure-includes-surprising-change-to-user-fees/ They got rid of the reduced VCP filing fees for stupid things like RMD's and loan defaults. Schedule of User Fees for VCP submissions, is revised to change the user fees to: $1,500 for plans with assets of $500,000 or less; $3,000 for plans with assets of over $500,000 to $10,000,000; and $3,500 for plans with assets of over $10,000,000. (4) All other reduced or alternative fees previously set forth in Appendix A, .09, no longer apply. so the small business which is likely to have loan failures and missed RMD's pays $1,500 or $3,000. Plans over 10 Million pay just $3,500. What a nice thing for the mega corporations. What an awful decision. I hate to be political but I swear the most important thing for this administration feels like undoing as much as possible from the prior administration.

RBG, yes yes yes. I go back to my original point, you cannot tax someone on money they NEVER got. Period. You just can't do that. And no one does.

Nobody, and I mean nobody, uses the $10,000 provision you indicate, because it involves using non-plan assets as collateral. I've read about it in books but in my lengthy career I have never seen it done.

Now, I of course know exactly they mean by this. But I thought maybe you would do the rest of the readers a favor and explain the practical implications of this statement with an example? Because to me.... errr... I mean to the other readers , it might not make sense at first glance.

Gee why didn't I think of that