could be me maybe not

Wow. A kindler and gentler IRS. Thanks.

Unless of course he is schizophrenic and can be judged by a special blue ribbon panel of physicians (who otherwise specialize in certifying municipal disability pensions) to in fact be two or three separate persons in which case each may perhaps up to get $50K.

Why thank you, my Botox shot must be working. At least I had the right decade.

wasn't it RR 89-202

Cat got fish's tongue? Consider looking here: http://yoyo.cc.monash.edu.au/~bunyip/primes/

My dashing orangutan french teacher, Charles Francois Heston, once explained that the use of foul terms evidenced a limited vocabulary.

He's a zero unless he is excludable on the basis of age or service.

gold, that's a wild and wooly approach that you are vetting but my bet is that it has a 0% chance of success. Do you have an actuary that signed, or is willing to sighn, a Schedule B that reflected a reduction in benefits or costs as a result of such a waiver? If so, hope he is retiring soon. I don't mean to sound sarcastic, but effen is right. Your position is invalid unless the waiver is recognized at the time of plan termination, not before.

Don't you also have the option of contributing up to the full funding limit without penalty even if it is not deductible? Another EGTRRA thing I think I thaw.

Someone I know experienced abajeb's issue. PBGC will receive forwarded mail from the 2004 address (very slowly) but the Baltimore filings are being returned to sender as undeliverable. To make things worse, the delivery box from the 2004 instructions is still active and I know of one that was sent there and signed for-but it was not the PBGC that took it. The PBGC says they "changed it's vendor" so whoever accepted it is not representing them. Apparently this address issue is not an uncommon problem. I don't mind stating that the PBGC is an inept and abusive organization from my experiences with them, and with only one exception the representatives that I have dealt with at diferent levels including problem resolution and coverage determination were incompetent. Other than that, they're terrific.

You may resemble my remark, but you could not be the pulchritudinous board member that I am.

Relying on memory alone, I have always been of the impression that the CSV of a life insurance policy was not required to be reported on the 5500. If the instructions now say they must, then I think something changed. If the instructions say yes, then I agree the filings should be amended. But I an not at all sure that they do in which case I would not amend prior filings, just add them as other income.

Yes, and it is presently undergoing IRS audit. I don't suspect that would be much fun to be part of, but I'd pay to read a transcript. Suggestions for your client? Try to pass without the QSLOB rules. Want more advice? Much more information needed. What are the facts and why is this coming to light now?

Do a lot of those at the yacht club, Ned? touche

Nothing requires a QSLOB claim. Isn't a late filing a non-filing? If so, you needed to pass coverage and nondiscrimination without regard to the QSLOB status, right. That is my impression. Is that an option? If not, it sounds like the sponsor has lots of exposure. Maybe I'm cynical, but I have recently seen bogus QSLOB claims that had non-filings. And people (who are occassionally-not regularly) on these Boards were responsible for the bogus work.

Uh, yes.

Agreed. Many problems.

Welcome back to the fishy. Thought you'd pulled a Mike P on us. Now that the facts are clearer, yup, an amendment by 10/15 is the answer. As Tom said....

Amen to that.

Why would a corrective amendment be needed? Why isn't this person simply eligible under the terms of the plan?

epicenter?

Is the person married?

That's it Tom, your next pension song, by Boston, "More than the Gateway" to the tune of "More than a Feeling" circa 1978.

My obviously less evolved ESP could not sufficiently understand the facts pertinent to the situation.

The vesting requirement comes from the 11-(g) requirement that a corrective amendment provide benefits that are "meaningful". If you are not amending, you don't fact this issue. But then again, that is what DFerrare already said so I'll just say ditto.