WDIK

http://benefitslink.com/boards/index.php?s...opic=26356&st=0

The instructions for Schedule SSA, line 4, box h, indicate that you should enter the value of the participant’s account at the time of separation. If the account was not valued at the time of separation (for example the plan has a single valuation date) I would use the account balance as of the next valuation.

Your premise seems logical to me.

banality: I thought that perhaps you could stand some encouragement by some good things.

Does it bother anyone else that the cans of fruit cocktail you purchase usually have only one-half of a maraschino cherry? (Just for the record, the fruit cocktail comment was meant as a commentary of the somewhat disjointed nature of that entire thread and was not directed at anyone in particiular.) With regard to chris's post, it is my opinion that such an amendment would not be allowed because of the notice issue that he brought up.

Apples - Effective date of the plan. Oranges - First date deferrals can be made. Peaches - Compensation allowed. Pears - Pro-ration of limits. Let's either address one issue at a time or have some fruit cocktail.

I just came across a username that I would like to add to my favorites list. Wislindixie

Blinky's post is right on target as usual. (And Bird's) Sometimes its difficult to see the forest for the trees.

I would be wary of allocating to a partner's account without first allocating an appropriate amount to the accounts of the rank and file employees.

There is a little help here.

Code Section 411(a)(10) deals with changes to the vesting schedule.

It would depend on the available language in the prototype document. For example, I think that the non-standardized prototype document sponsored by Accudraft allows different definitions of compensation for different contribution types.

If they are excluding the bonus from compensation, how can there be deferrals/matches based on the bonus?

I am not disagreeing with the prior posts. Perhaps it would have been more appropriate for me to say that the amendment should apply on a prospective basis as coordinated with the plans accrual requirements. There are certainly scenarios where an individual who had already qualified for participation and an accrual during the plan year could have a new entry date based on the amendment that would exclude the employee as an "active participant." As a completely separate issue, I would certainly not want to be the one communicating employees that although they were once considered active participants they no longer are.

On a prospective basis.

chris4013: Are you talking about pro-rating the limits?

While I certainly am not capable of rendering a legal opinion on 1.401(k)-1(g)(i), I would have read the section as implying that you can use either the twelve month period that corresponds to the plan year, or the twelve month period that corresponds to the calendar year ending within the plan year. The section itself does not address a short plan year scenario. Good point. I'm not sure what chris4013 is looking for.

It appears several different things are being mixed together. The first post talks about prorating compensation for the ADP test. The prior post gives a cite that pertains to safe harbor plans where the ADP test is deemed satisfied.

Prior Discussion

Whether or not it is a prohibited transaction depends on any relationship that exists between the plan and its fiduciaries and those involved in the sale of the property. Debt-financed property can be allowed in retirement plans, but can result in unrelated business taxable income. Mortgage payments are made from plan assets. The real estate must be valued at fair market.

You Burnt the Bird? A Dozen Reasons to Be Thankful! 1) Salmonella won't be a concern 2) No one will overeat. 3) Everyone will think it's Cajun Blackened. 4) Uninvited guests will think twice next year. 5) Your cheese broccoli lima bean casserole will gain newly found appreciation. 6) Pets won't pester you for scraps. 7) The smoke alarm was due for a test. 8) Carving the bird will provide a good cardiovascular workout. 9) After dinner, the guys can take the bird to the yard and play football. 10) The less turkey Uncle George eats, the less likely he will be to walk around with his pants unbuttoned. 11) You'll get to the desserts quicker. 12) You won't have to face three weeks of turkey sandwiches

The answer to my question is found in Ltr Rul 200123070. The IRS ruled that a non 5% owner employee who rolloed over a distribution to an IRA after attaining age 70-1/2 but before retirement could delay the first RMD from the IRA until the year following the year of the rollover.

But then wouldn't the IRA be required to make a minimun distribution?

Yes.

We received a similar letter. If I recall, they mentioned something about trying to coordinate information for an upcoming change in agency responsibilities.