austin3515

Actually, one does not have to ask. One might instead say what I said which is that it needed to be signed in 2017. Same message, no hurt feelings

To avoid any misinformation on the public record, we received ours from FIS back April 2017. Of course if you wanted to use it for your clients in 2017 it needed to be signed in 2017. I ssume they did all of their documents at the same time, but we use the Corbel version.

With the early participation for the Doctors only I would be afraid that if an IRS auditor saw that plan design, they would insist on seeing that TRA 86 restatement or something like that to punish you for being so obnoxious. Anyone else have a similar reservation? You are somewhat beholden to them under audit and they have every right to ask a lot of questions that can be time consuming. Perhaps that design is the basis to expand their audit to be much more extensive than it might otherwise have been...

Plan years begining after 12/31/18. Actually perhaps this explains the delay. Recordkeepers rightly said they need more time to implement the change. This certainly gives everyone time to adjust their systems. Perhaps the voice of reason was there whispering in the Uncle Sam's ear...

Tom Poje is pretty Guru though and he says no... Although I am better known as an International MAn of Mystery (as opposed to a pension guru) I too eventually learned that you either are an HCE today or you are not. But when "the Tom Poje" says he wouldn't do it, it certainly gets my attention!

http://docs.house.gov/billsthisweek/20180205/BILLS- 115HR1892SAmdt2.pdf 41113 and 41114. Back in baby!

How about this: Younger Owner makes $50,000 and gets a 3% SHNEC for $1,500. Older NHCE makes a $100,000 and gets $$3,000 SHNEC. Sounds like I can do a PS contribution of $1,500 for the younger owner t get him or her a total of $3,000. This might be the coolest thing I have learned on these boards in a year... Probably not going to help very often, but really cool...

Correct me if I am wrong, but did MargeM not make the crucial point here? You CAN give the lower paid HCE $5,000 and the higher paid NHCE $5,000 and still pass testing on the basis of allocations? Safe harbor/not safe harbor might be the subject of my thesis in my pension Ph.D studies, but I just want to know what I can do for a client.

My secret trick is: If you have a $100,000 cash and a $5,000 loan, roll your $100K to your new employers plan, then take a $5,000 loan and make a rollover to an IRA (the advantage here is the 5498 from the custodian to prove to the IRS you did it). This way you pay no taxes and you still have your $5,000 loan. obviousluy you have to be able to rollover right away and the plan must allow for loans and you must have enough money to do all of this. But a lot of times it lines up.

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.