Calavera

With the range certification by 9/30, the actual AFTAP needs to be certified by 12/31. Don't even need to certify 100% or higher, the range certification of 80% or higher should be sufficient.

For the EOY val you need to use actual net earnings, so if benefits are defined as a percentage of current compensation, someone would need to correct it. Just some suggestions: 1. Confirm how benefits are defined and go from there. For a DB plan it may be a percentage of an average compensation. For a CB plan it may be an amount specified in the plan document without referring to any compensation. 2. Ask prior actuary if it was assumed that both companies adopted the plan or ask him to justify compensations used for calculations. 3. See if you can get copies of all Schedule SBs and copies of tax forms to compare earnings and deductions. Or just tell this prospect to find another TPA, since you are not interested in this case

See if you can change any assumptions to at least reduce the 2024 minimum required contribution.

Is it beginning of the year valuation?

Just a reminder that 110% is calculated after the payment and the target liability could be used for the ratio. So, when majority of benefits belong to the retiree, it's usually not too hard to overfund the remaining target liability by 10%.

I vote that 110% rule still applies.

On a contrary, I would never say that this person enters on 10/1. I believe this question was discussed multiple times over many years, and people always had different opinions. Some from this board even changed their opinions over time. I am not aware of any official cites covering this question. The only article I found support entrance on 1/1/2025 in this case - https://williamskeepers.com/retirement-plan-deficiencies-a-look-at-the-most-common-mistakes-part-2/ And this is what Google's AI said: The entry date, coinciding with and next following one year from your hire date of 1/2/2021, is 1/2/2022. Explanation: The question specifies that the entry date is one year after the hire date. A year from 1/2/2021 is 1/2/2022. The phrase "coinciding with and next following" means the entry date is either exactly one year from the hire date or the first date after that which is designated as an entry date. Since you were hired on the 2nd of January, one year from that date is also the 2nd of January. Therefore, the entry date is 1/2/2022.

I would disagree with this. Callie completed one year of service at 1st second of 1/2/2023 and therefore cannot enter on 1/1/2023

I would also suggest recommending in writing to refile 2024 taxes, since that contribution was not deductible in 2024, just to have it on record, so you wouldn't be blamed later.

I assume it is a standard DB plan and not a cash balance plan, so I don't think amending the interest rate would affect the offset calculations at all. But if plan already terminated or deep in the process, I agree it may be not wise to amend. Method suggested by Lou S. looks very reasonable and defendable in case of any audits.

I like this approach You can amend the lump sum interest rates bringing payout up to 415 limit.

Not really. Depending on the vested service definition under plan document this person will either have 2 years of vesting service or 1.91667 years of vesting service.

I would disagree. The participant doesn't need to be employed on the anniversary date to receive vesting credit. Under elapsed time rules this participant will receive either 9 or 8 months of vesting service depending on the definition of vesting service. Some plans give 1 month for 1 day of work.

For a shared interest QDRO, AP is usually the beneficiary on the portion of benefits that are subject to a QDRO. You have one J&S factor and one coverture fraction. Result should be the same. What am I missing?

If a 3-year average W2 compensations was established already, you may not need any current compensation for a defined benefit plan. However, you may need a reasonable compensation paid for services, but this is the question to an accountant/tax advisor.