Calavera

Rates also could be found at http://www.datair.com/rates.htm Just in case anybody still wondering about AFN and HATFA http://www.dol.gov/ebsa/pdf/fab2015-1.pdf

What is the business structure, partnership or corporation? If partnership, it is a one-person plan. If corporation, it is not a one-person plan.

I suggest to postpone your profit sharing contribution until next year. I have seen too many clients where the expected earnings of $X become 50% of $X by the end of the year, and could not support a contribution that was already made.

Start a defined benefit plan with a solo 401k plan, and DO NOT invest in real estate.

1. I am not sure if it is allowed to forfeit any benefits under a DB plan 2. What plan document says about commencement? Has to commence at NRD Has to commence at NRD but may defer, however not past RBD Commence at later of NRD or actual request for benefit etc. 3. If your understanding (AE to the current date) is coming up from reading 401(a)(9)©(iii), I think this section is applicable only for the retirement from active employment. 4. Assuming all of them terminated before 70 1/2, and commencement is not allowed later then RBD date, I would actuarially increase it to RBD, and then pay them missing payments from RBD with reasonable interest. As it was mentioned above, there is no clear guidance on this issue.

I am not aware of any exemption from the applicability of this rule just because plan is covering only HCEs.

I think yes, and it should be 110% funded.

I found table titled 1971 TPF&C Male for ages 16-110 in one of our systems. All numbers match your table.

A plan violation would exist unless a plan sponsor gave a suspension of benefit notice to a plan participant (assuming the suspension of benefit notice language is in the plan document). I am not sure if you can amend plan now for RASD and implement option b) from your original post. You need to consult ERISA attorney. This is a perfect example of a bad consulting that may result in a lawsuit against TPA

Actuaries don't but very good actuaries do.

http://benefitslink.com/boards/index.php?/topic/55122-allocation-of-contribution/?hl=allocation

Interest credit should be considered a part of accrued benefit and not a part of actuarial equivalency, and therefore, in my opinion, could not be suspended.

I believe your question is still valid. Jim was trying to address several different issues in one example such as: missing RMD's payments, actuarial increases post 65, SOB, actuarial increases post 70 1/2, offset of benefits by benefits received, etc. So the way I see it in your case: Step 1 - Does plan provide for accruals after NRA to be offset by actuarial increases in the benefit? Step 2 - If no - follow first part of example 10 until age 75. If yes - follow first part of example 11 (my version) until age 75. However, if you think that the offset is not permitted after age 70 1/2 even if the answer to the Step 1 question is "Yes", then follow example 10.

Ex 10 and 11.xlsxWell, it took me a while to dig through the examples 10 and 11 in Jim's article. I have to say that I agree with the Example 10 solutions, but disagree with the Example 11 solutions. 1. I believe Jim actually miscalculated the age 71 monthly benefit amount by accidentally projecting it to age 72. 2. I still disagree that post MRD need to provide both, actuarial equivalent and accruals, when plan provides for accruals after NRA to be offset by actuarial increases in the benefit. There are two reasons for my disagreement on post MRD calculations: 1. A-9 of 1.401(a)(9)-6 states that the actuarial increase required under section 401(a)(9)©(iii) for the period described in A-7 of this section is generally the same as, and not in addition to, the actuarial increase required for the same period under section 411 to reflect any delay in the payment of retirement benefits after normal retirement age. (emphasize mine) 2. Gray Book 2007-17 states that “any additional benefits accrued after that date” are those required under the rules of IRC §411(b)(1)(H), which provide that an accrual for additional service during a year may be offset by an actuarial increase for delayed retirement. Attaches is my Excel file development of Jim's solutions and my version of the Example 11 solution. Please refer to David Rigby's and My 2 cents' disclaimers above and check with plan's ERISA counsel second.

I believe the key is in the following question: Does plan provide for accruals after normal retirement age to be offset by actuarial increases in the benefit? The Gray Book emphasize "may be offset", which means it has to be spelled out in the document. Look at the difference between Situation 10 and Situation 11 in the Jim's article.

Also need to be sure that beneficiaries of trust are not stuck with 5 year distribution upon death, and can take the distribution over life time.

I guess it is not clear from the law perspective. Since it was covered as the beginning of plan year, you will be filing 2014 PBGC premium, and you will pay full premium amount without any proration, I would probably treat it as covered for the 2014 tax deduction purposes. I would suggest to run it by ERISA attorney and/or tax advisor.

Did you actually request from PBGC to remove the DB plan coverage?

I never had a case when I wouldn't be able to replicate the results at the end of conversion. Generally, as long as the prior actuary is communicating with you, you will be able to match prior year results. However, often you discover that the issues with the replication you had in the beginning of the process are due to prior actuary errors. Then it would be about nature of the errors, materiality of impact, and decisions about letting it go or redoing the prior work. I guess if the prior actuary is unresponsive, you may have issues, but I never was that lucky. It may be a good idea to mention it in your engagement letter.

Not sure but I think transferred out of plan who is not 100% vested yet could generate the difference.

There were 2 very good articles on post-NRA distributions by Jim Holland that could be found here: http://www.asppa.net/Document-Vault/PDFs/PCFALL2012.aspx http://www.asppa.net/Document-Vault/PDFs/PCWINTER2013.aspx Hope it helps.

Depending on the size of the plan, PBGC coverage, and how late the contribution was, you may need to notify participants and you may need to file PBGC Form 10.

T-10 net of '51 GAM for age 63 is .00132

Be sure that a part-time employee have never worked more than 1000 hours per year since original date of hire.

I don't think so. It is Dad B's ownership that is attributed to Child #4. Since all children are over age 21, and each has ownership in only one company, they all should be ignored. Therefore, I believe there are no control groups in this example.