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Everything posted by Calavera
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Actuarial Equivalance
Calavera replied to Josette's topic in Defined Benefit Plans, Including Cash Balance
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. -
Actuarial Equivalance
Calavera replied to Josette's topic in Defined Benefit Plans, Including Cash Balance
I would use the ratio of an immediate factor to a deferred factor. -
If an employee worked 83.33 hours in April of 2022, the entry date maybe October 1, 2022.
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I think you will find these useful:
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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.
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Looks like your initial computation period is from March 1, 2022 through February 28, 2023.
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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.
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Are retroactive QDRO benefits a thing?
Calavera replied to CSC's topic in Qualified Domestic Relations Orders (QDROs)
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. -
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.
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Control Group and PBGC Coverage
Calavera replied to Catch22PGM's topic in Defined Benefit Plans, Including Cash Balance
I would actually want to be covered by PBGC. For a really small PBGC premium payment, you get full 401k/PS/CB deduction. -
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."
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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.
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Cash Balance Contribution Deduction
Calavera replied to Catch22PGM's topic in Defined Benefit Plans, Including Cash Balance
If this CPA really thinks that it cannot be deducted for 2021, your client may need another CPA. -
lump sum as of when
Calavera replied to SSRRS's topic in Defined Benefit Plans, Including Cash Balance
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. -
110% test related
Calavera replied to Jakyasar's topic in Defined Benefit Plans, Including Cash Balance
See if you can justify lower credited interest rate, or retiring at later ages, or both. -
110% test related
Calavera replied to Jakyasar's topic in Defined Benefit Plans, Including Cash Balance
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. -
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.
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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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Don't know much about market ROR ICR, so just thinking out loud. Do you have to test it on actual ROR, or on some arbitrary long term ROR, since person is not really retiring? Can you say that using 3 or 4% for the meaningful benefit testing is acceptable (no matter what the actual ROR in a particular year?
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Unfortunately not just small CB plans. Which brings whole different set of issues that plan sponsors are thinking about CB plans in terms of 401k plan, that in order to allocate something they actually need to contribute that something. Or because they already withheld something from partners, now they have to contribute exactly what they withheld, not more, not less.
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Controlled Group Question - Family Attribution
Calavera replied to metsfan026's topic in 401(k) Plans
Only 1, 2, and 5. Adult son owns 100% of Company 4 and it is not attributable to parents.
