Bird

We've done this often. You have to have some cash. Estimate the amounts, transfer in-kind, and even things out with cash after you know the actual values transferred.

The EZ does not reconcile assets; it only asks for contributions. You can include other docs related to the plan or you can include your 3rd grade report card; same effect.

Somewhere buried in the regs it says you can calc it on a cash basis (in many more words than that). I don't recall anything about having to be consistent so I'd say you could change.

We exclude post-year end comp after severance and thus would not include it. The problem that arises is when 401(k) contributions are made on said comp. It happens infrequently enough that I couldn't tell you how we deal with it but I think we exclude everything from testing and just show the contribution in the financials.

I agree with comments above, but would add that you haven't provided their termination dates. If it's a small company, odds are pretty good that they didn't sell the company and step out the door, never to return. It's not hard to make a case that they did something thru the end of the year and term'd Dec 31 or later. As noted, it is important to know whether it is an asset sale or stock sale. If it was an asset sale, then the old company might have existed for some time after the sale (and that is where it is easy to justify employment thru the last day of the year). If it was a stock sale, well, then the new owners would be footing the contribution bill so you want to be darn sure that everyone knows the implications of the termination dates.

I don't see that it matters. Yes, if by "account charge" you mean "total expenses" - for the same fund. There are actually funds with low expenses that can be crappier than funds with higher expenses.

agreed. Good luck gtting the custodian to do it. The refund (that didn't happen) should be withdrawn as an excess contribution. Shouldn't be too difficult at that end.

Thay appear to be capital contributions, not values. What do you think?

Yes, assuming they are both participating employers. Of course you have to make the usual adjustments to the self-employed income, which can be tricky but not impossible since SS taxes are not applied over the limit.

Yup. We should probably do it more.

I was kind of leaning this way. Just show a big loss and allocate it currently. Although I think if there were ongoing contributions it would not yield a "perfect"' result but probably close enough.

Interesting although nothing surprises me any more. Sorry but I have no experience with this.

Um, I thought comp for SIMPLE matches was not limited. He contributed more than 3%, or 3% on comp over the otherwise applicable limit?

I'm not sure what to make of this. Are you saying that they might report things on a W-2 but then not include it as wages on the partnership return? That possibility never occured to me. I'd think that would be problematic for reconciling tax payments.

If the loss has not already factored in those expenses, then I'd say you have to factor them in, increasing the loss.

You mean somebody bought an interest in a LP, say 25% of the total LP, and it's been carried at 100% of the LP value? Of course that is wrong. I imagine it is simply poor communication marinated in stupidity. Somebody buys something like that so you know they are stupid or at best had stupid advice, and the stupidity snowballs from there.

After tax contributions are..."after tax" so IMO they have no impact on compensation. No grossing up or down or whatever.

I agree that this is improper, but it happens all the time (the lame reason that I've heard is that it makes withholding easier), and I have not heard of the IRS doing anything about it. So we deal with it. I agree with Bri's analysis.

I think you have to.

none of the above If it says "on" (not "on or before" which I doubt) I think you count service from the original hire date. Assuming it is one year eligibility, he won't have a YOS as of 5/4/2020, and assuming the measuring period switches to the calendar year, then he won't have a year of service for 2020. Presumably he would have a YOS in 2021 and become eligible 1/1/2022. Obviously making some assumptions.

I can't think of any time that we've done that, and probably the reason is we've never even considered offering it. Our (TPA) fees are almost always paid directly by the employer, so it doesn't come up, but when we have large fixed base fees for recordkeeping, I've always said you "have" to allocate them pro-rata.

not really

That is what the successor plan rules say, yes.

I think you mean they will have a new company with a different EIN If same ownership, successor rules apply.

Still mildly curious if they were "distributed" (as in removed from plan assets) or being carried as defaulted loans, although it's not relevant to the discussion. (If they were distributed with no distributable event I think that is a bigger problem than a few dollars of interest.) If at all possible I try not to argue with auditors or recordkeepers and this is basically an argument between those parties so I am doubly incented to bow out.