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Calavera

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Everything posted by Calavera

  1. Or the document may say: no spouse and no beneficiary form - no benefits
  2. It looks like you are using the end of the year valuation date. If the valuation date was not changed in any of the four preceding years, you can change it to the first day of the Plan Year, i.e. 1/1/2022. If it's not enough to get your minimum contribution to $0, see Nate S' comment above.
  3. 1. If plan was frozen in 2017, you would use the 2017 limit of $215,000. 2. If the freeze amendment specifically allowed the future $415 limit increases, you will use the current $415 limit. 3. Based on the plan document definition of years of benefit service and years of participation, owner may have 4 years of participation for $415 proration purposes. If none of this helps much, just unfreeze the plan.
  4. I am not sure it matters how plan got frozen. So this person accrued benefits for 5 years, and then plan got frozen. Wouldn't frozen plan satisfy 401(a)(26) automatically?
  5. Not really. Annuity multiplied by a ratio of immediate to deferred factor will give me an actuarially increased annuity which will be compared to an accrued benefit. The greater of amount will be the starting point for the next year comparison.
  6. I would use the ratio of an immediate factor to a deferred factor.
  7. If an employee worked 83.33 hours in April of 2022, the entry date maybe October 1, 2022.
  8. I think you will find these useful:
  9. Your first computation period is 3/1/22-2/28/23. Since an employee worked only 250 hours in this period (<500 hours), an employee may incur a one-year break in service for the eligibility purposes. You need to check your plan document on how the year of service for the eligibility purposes, and the one-year break in service for the eligibility purposes are defined, and if this break in service reset the eligibility computation period to the 12 months from rehire date.
  10. Looks like your initial computation period is from March 1, 2022 through February 28, 2023.
  11. Sorry, should have mentioned that this is a calendar year plan and there are no any weird gotcha provisions. Assigning will be proposed by the actuary to the plan sponsor over email in order to save some PBGC premiums, and the plan sponsor will reply agreeing to the split. Having two separate checks certainly will not have any issues. Concern was simply raised due to it being one contribution instead of two separate contributions and split would not be known until the actuary would do all necessary calculations. Thank you all.
  12. A $1,000,000 contribution was made to a db plan on 7/1/2022. Are there any problems assigning a portion of this contribution to the 2021 plan year, i.e. $700,000 will be shown on the 2021 Schedule SB, and the remaining $300,000 will be shown on the 2022 Schedule SB?
  13. Take a look at Rev. Proc. 2021-30. I recall there was something about overpayments under $250.
  14. Since your ex didn't commence his benefits yet, if you start your benefits before his age 65, your full share will be reduced due to an early commencement. His retirement plan administrator should provide you, upon your request, the calculated amounts of your benefits under scenarios of retiring now and retiring 3 years from now (at his age 65), so you can see what is the reduction, and then decide if you would want to take it.
  15. Just a side note - If in-service distribution is allowed, participant may take a full distribution of the benefits as a lump sum and use an account method for calculating RMD.
  16. I would actually want to be covered by PBGC. For a really small PBGC premium payment, you get full 401k/PS/CB deduction.
  17. Offset is applicable post MRD as long as plan has the language for the "greater of" calculations. Here is excerpt from 1.401(a)(9)-6 Q/A-9: "The actuarial increase required under section 401(a)(9)(C)(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." Here is also excerpt from the 2007-17 Gray Book: The phrase “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."
  18. 1. In my practice (following plan document of course) when plan is ongoing and someone started in-service distribution, we would recalculate benefits each 1/1 to see if the value of accrual is over the value of benefits received. If yes, benefits will increase for the difference. If no, benefits will stay the same. 2. It is also possible for a participant to reach the 415 salary limit.
  19. If this CPA really thinks that it cannot be deducted for 2021, your client may need another CPA.
  20. As Effen said, you will get multiple answers. One of them is LS is recalculated as of 3/1 and you add 2 monthly payments with interest for 1/1 and 2/1.
  21. See if you can justify lower credited interest rate, or retiring at later ages, or both.
  22. Not sure what you meant by an annuity option, so here what I have seen. Participant elects lump sum, but you pay only what you can (i.e. annual benefit) and bring the remaining lump sum amount up 1 year with interest. At any time you can pass 110% test, you pay the remaining lump sum. And just a reminder, 110% is measured after the distribution. Liability is calculated without this person. Asset is calculated subtracting the payment to this person.
  23. Is plan underfunded, overfunded, or underfunded with future contribution to make it whole? In my experience, it is always a bad idea, especially if you need to distribute the exact amount at 415 limit. Value of funds leaving the plan almost never equal the value of funds received by IRA.
  24. I think you do have control group issues. The way I understand it, you have 3 controlled groups, since the exception to spousal attribution will not apply to Company B: 1. B with A and C 2. A with B 3. C with B For Company C to have a pension plan, Joe has to be in the plan.
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