WDIK

Please clarify what you mean by this statement.

http://www.deferral.com/dts/content/general/overview.asp

Hashed and rehashed. You can find additional threads as well.

Isn't their Windows version still in beta testing?

What types and amounts of contributions are currently being made by the employer? Edit: Also, approximately how large would the 3% top-heavy contribution be?

Chuck: We are in agreement. It looks like you are the only one who actually stayed focused on the original post. I need to make it a habit of reviewing the entire thread rather than just commenting on the newest post. It just goes to show that even when I'm right, I'm often wrong.

Line 1h is for operating payables, and the instructions for that line use the terminology total amount of "obligations" rather than distributions. It also does not use the terminology "approved as of the last day of the PY". Instead it states "have been approved for payment by the plan but have not been paid". Line 1g is for benefit claims payable. The instructions for that line use similar wording - "benefit claims that have been processed and approved for payment by the plan."

Schedule C, Line 19 (2003 Form)

I do not think that the exception listed in 3(d)(1) applies in your situation. The plan includes investments in a Pooled Separate Account, but the plan is not a PSA.

I should have read jquazzas first post more carefully before commenting on his second post. Unless I'm missing something, I must agree with his comment that the tax free accumulation of earnings inside the Roth makes a difference. Traditional IRA ---------------------------------------------- ** Income *IRA Cont *Cum Val Tax Paid Y1 4549.93 3275.95 *3275.95 356.71 Y2 4549.93 3275.95 *6879.60 356.71 Y3 4549.93 3275.95 10843.39 356.71 Y4 4549.93 3275.95 15203.68 356.71 Y5 4549.93 3275.95 20000.00 356.71 Y6 ***0.00 ***0.00 22000.00 **0.00 Y7 ***0.00 ***0.00 24200.00 **0.00 Y8 ***0.00 ***0.00 26620.00 **0.00 Y9 ***0.00 ***0.00 29282.00 **0.00 10 ***0.00 ***0.00 32210.20 **0.00 **************Tax on Savings Earnings Earnings Cum Val Y1 917.27 **0.00 **0.00 *917.27 Y2 917.27 *91.73 *25.68 1900.57 Y3 917.27 190.06 *53.22 2954.68 Y4 917.27 295.47 *82.73 4084.68 Y5 917.27 408.47 114.37 5296.05 Y6 **0.00 529.60 148.29 5677.36 Y7 **0.00 567.74 158.97 6086.13 Y8 **0.00 608.61 170.41 6524.33 Y9 **0.00 652.43 182.68 6994.09 10 **0.00 699.41 195.83 7497.66 Total at Distribution: 32,210.20*.72 + 7,497.66 = 30,689.00 ---------------------------------------------------------------------- Roth IRA ---------------------- **Income Tax Paid Roth Cont Cum Val Y1 4549.93 1273.98 3275.95 *3275.95 Y2 4549.93 1273.98 3275.95 *6879.79 Y3 4549.93 1273.98 3275.95 10843.39 Y4 4549.93 1273.98 3275.95 15203.98 Y5 4549.93 1273.98 3275.95 20000.00 Y6 ***0.00 ***0.00 ***0.00 22000.00 Y7 ***0.00 ***0.00 ***0.00 24200.00 Y8 ***0.00 ***0.00 ***0.00 26620.00 Y9 ***0.00 ***0.00 ***0.00 29282.00 10 ***0.00 ***0.00 ***0.00 32210.20 You can tie in the $1,521.19 difference if you accumulate with interest the taxes paid on the "savings" Y1 0.00 Y2 25.68 Y3 81.47 Y4 172.35 Y5 303.95 Y6 482.64 Y7 689.87 Y8 929.26 Y9 1204.87 Y10 1521.19 **Edit to try and line up the tables** Okay, I give.

If you count the "other savings" in one scenario, you have to factor them into the other scenario as well. It doesn't matter which pocket I take the money from to buy a pack of gum, I've still got 40 cents less overall.

Responses of various service providers after taking the DOL representative training course 2: Mechanic - "This additive will help your engine run better, but I can’t tell you which fluid it is used with." Physician - "Here’s your prescription, but unfortunately I can’t tell you the appropriate dosage." Lawyer - "If you don’t structure that transaction properly, you’ll be thrown in jail. Good luck!" Actuary - "You must complete your funding by September 15th, but I can’t tell you the required contribution amount." WDIK - "I have no idea, let's post on the Benefits Link Boards." (Course 1)

One of a number of prior discussions.

Harwood: Your direct approach is much better than my attempt at subtlety

Is this a corollary to "Pascal's Wager"?

Was the IRS successful? In what way are the circumstances you mention the same as those described by Christine? In what way might the be different?

Several Points: 1. I felt the link was relevant because: a. It points out that the administrator must make an interpretation of plan language with respect to distributions. b. It points out that the a consistent policy should be adopted and followed. 2. A number of variables regarding the timing and notifications of distributions may apply in addition to the example language given, including: a. Forced cash-outs for amounts under $5,000. b. QJSA/QPSA rules. c. Administrative costs associated with terminated participant accounts. d. Problems associated with missing participants. e. Application procedure. f. Valuation dates/methods. 3. If plan language indicates a "date" when the distribution will be made, it is my view that the administrator should be proactive in notifying the participant in order to follow the document. 4. If plan language indicates the distribution will be made at the participant's request, it is my view that the administrator should be proactive with the participant. While there are some instances it may not be desirable for the employer to complete the distribution, I think there are more instances where it is beneficial. 5. Terminated participants are entitled to other disclosure items anyway (i.e. SAR) so why not provide distribution materials as applicable? 6. Now I have gotten too long-winded.

The following may be of some help: http://benefitslink.com/boards/index.php?s...opic=22887&st=0 (Specifically the third paragraph of Jed Macy's comment and pax's comment.)

Are there employees other than the husband and wife in either entity?

http://www.dol.gov/dol/allcfr/Title_29/Par...520.104b-10.htm

I am fairly sure that this statement is true with respect to any penalties that might be imposed. What I'm not sure about is if this also means the DFVC program is available. Thanks for the opinions thus far.

Box 3d may cover both contributions. Under the instructions for line 4c(5) of Schedule T, it indicates when an employee is considered to be "benefitting." It states in part: "[A]n employee is treated as benefitting under a plan...that provides for...matching contributions under Section 401(m) if the employee is eligible to...receive allocations of matching contributions even if none are actually made or received."

In the context of the thread, I took TBob's question to be rhetorical in nature. Minimum required distributions are not subject to mandatory 20% withholding because they are not eligible rollover distributions. If the plan document language was appropriate, and a currently employed 70-1/2 year old non-owner elected an in-service distribution, I do not think that this qualifies as a minimum required distribution.

Responses of various service providers after taking the DOL representative training course: Mechanic - "I'm not sure why your car is making that noise. You ought to read your owner's manual." Physician - "I'm not sure why your knee is aching. You ought to read an anatomy book." Lawyer - "I'm not sure if that is legal. Get back to me after you've finished your course on tort reform." Actuary - "I can't calculate that premium right now, but why don't you browse through these mortality factors." WDIK - "I have no idea, let's post on the Benefits Link Boards."

Okay, maybe I don't agree with your interpretaion of the 80-120 Participant Rule. I think where the confusion lies is in the distintion between the general rule and the special 80-120 Participant rule. The general rule is that a plan with 100 participants or more must file as a large plan, while a plan with fewer than 100 participants files as a small plan. As an exception to this general rule, you can keep filing as a small plan if you previously filed as a small plan and the count doesn't exceed 120. Conversely, if you previously filed as a large plan, you can continue to file as a large plan if the participant count does not drop below 80. You are not required to use the exception. You can fall back on the general rule, so if the participant count is 99 or less (even if you filed as a large plan the previous year) you can file as a small plan.