WDIK

Is it a pooled investment account or does each participant have a separate investment account?

3.5 out of 4 stars I would've gone four, but the performances were a little wooden.

Is it possible that you reimburse the client and then have appropriate fees paid to you from the plan?

There most certainly are, and yes it is. The shadiness of any plan is more a result of the shadiness of the plan sponsor as opposed to the type of plan.

Dear IRS, Please consider the following suggestions: 1) Each IRS agent and/or processor should pass a competency test demonstrating that they understand when a 945 must be filed and when it is not required. This would not only save a significant amount of resources in paper, postage and IRS time, but would have medical benefits as well by reducing the heartburn, migraines and high blood pressure of pension practioners and their clients. 2) Each IRS notice of a proposed penalty for late filing of Form 5500-EZ should include a paragraph indicating that the IRS will pay the greater of $100 or 10% of the proposed penalty to the plan sponsor if the sponsor can show that the IRS itself confirmed receipt of both the extension and the form in a timely manner. While it may result in huge monetary losses, at least those who keep receiving such notices would feel like they have a sporting chance. 3) Implement a IRS psychic hotline so that small plan sponsors can call to determine if the plan's annual withholding liability will exceed the electronic deposit threshold. 4) Change your help line phone number to 1-IAM-AGR-AV8D

There should be a box to check for proration just before the plan size information. Then there is an entry for the number of months in the short plan year after the flat and variable rate premium calculations. (Positioning of these entry items is estimated.)

Yes, it is.

Does the amendment change the information that is in the Summary Plan Description?

Please accept my heartfelt sympathies as well.

That would be an affirmative.

You need to contact a paleontologist.

We were initially frustrated at the dealy in the release of Datair's software, but have no complaints about the filing process. It has gone smoothly. We would be completely done with our filings if a few clients were more proactive.

Could there be nonqualifying assets that are not properly bonded?

I disagree based on the following from the FAQs about The Delinquent Filer Voluntary Compliance Program found at http://www.dol.gov/ebsa/faqs/faq_dfvc.html. Is participation under the DFVCP available to all Form 5500 Series filers? No. The relief under the DFVCP is available only to the extent that a Form 5500 is required to be filed under Title I of ERISA. For example, Form 5500-EZ filers and Form 5500 filers for plans without employees (as described in 29 CFR § 2510.3-3(b) and ©) are not eligible to participate in the DFVCP because such plans are not subject to Title I of ERISA. Plan administrators may call 202.693.8360 if they have questions about whether the program applies to their filings.

This electronic filing stuff is as smooth as sandpaper...

Are they sure to the tune of $1,100 a day?

Does a "Plan Month" start on the 7th day or the 1st day of the calendar month? This goes back to Mr. Preston's point.

Mike is such a stickler.

The plan number issue I can understand, but an actuarial statement? The client has never had a defined benefit plan. The penalty was for the 2007 plan year.

A client received a $16,000 penalty notice from the IRS today for a plan that ceased to exist around 1994. Apparantly the Form 5500 actuarial information for this profit sharing plan was not signed by an actuary.

Ditto.

I believe that our software does not allow an entry on line 4m unless it is an individual account plan.

I believe that both options are available, but it may depend on the software you use and how the initial uploads were designated.

Your logic makes sense for me, but I was confused by the wording in my software instructions for this situation. "In the following example, there is a typo in the Signer ID or PIN and they do not match EFAST2 records. The filing will have to be amended and signed. The AckID of the original filing will have to be included in the amended filing. A PROCESSING_STOPPED EFAST status is very serious and should be corrected as soon as possible." I don't know the answer, but I was hoping those with more EFAST2 experience would be able to clarify.

Under the circumstances where the initial filing fails because of a missing or invalid USERID and PIN, should the resubmission be marked as an amended return in Part I or is it okay to resubmit as if it were the initial filing?