BG5150

But doesn't this discretionary match, on top of the SH Match cause the Top Heavy minimum to be due?

Does anyone do their general testing using the accrued-to-date method? We have a client whose prior TPA did their calculations that way and I can't make heads or tails of it. I understand the general premise, but Relius cannot do the calculation so it would have to all be done by hand. (Or, rather, spreadsheet) Questions: for average compensation: are you taking the average compensation over the measuring period? Last 3? High 3? Does the measuring period have a minimum length? 2, 3 years maybe? Is this a popular method to use? This is the first time I've come acrosst this since reading about it for an ASPPA test like 10 years ago.

I filed a zero participant/zero assets/non-final 5500 for much the same situation a couple years ago. No questions so far. But you never know.

Why not just amend the plan to allow immediate entry? Maybe one year for the match. The first year the people are hired, they aren't HCEs anyway.

That's 22 / 23 / 24. The following day, 4/9/16 was 22 / 32 / 42

Or was this one of the Trustees' accounts? Or another HCE?

Remember, though, if you have a safe harbor, you cannot impute disparity on that piece.

I get it now.

Um, pretty much none.

What's a Red Cup? (other than the thing I play beer pong with)

We don't even get pay stubs any more. They are available at anytime online, though.

Doesn't it come down tot he loan agreement? Can't you have a cure period that is less than the statutory max?

On that note, do the work per the ERISA counsel. Keep their written opinion on the matter, and in your correspondence to the client, add something to your cover piece such as: We have allocated your 2015 PRofit Sharing according to the plan document and according to the opinions (guidance, recommendations, etc) of ________ (name of ERISA person).

FWIW, then, I don't believe those who terminate after PYE is a valid business classification for the PY in question. The PS gets allocated as/of PYE, so, it's imposing a future condition on a current allocation.

Sorry. Missed the everyone in own group thing

But what about the middle classification? Those who terminate AFTER the plan year. Can you do that?

I'm not sure about the middle one. You allocate for the plan year given, and should be able to do it, ostensibly, on 12/31 (assuming calendar year plan). At that time, how do you know who will leave after that?

Oftentimes, landlords require first and last months rent plus at least a month rent in security deposit. So maybe this person doesn't have 3 months of rent saved up.

It overwrites it.

PS Grouping method: Owners in own group. All others in a single group. 4 owners at 25%. Son of one of the owners is a participant. Is he in his own group? Or with all others?

OK, thanks

So, we start with 14A and subtract the 179 deduction?

Side note: same thing for 1% owner and Key determination.

Yes. to your question. Earnings calculated tot he point of correction. Your earnings calc is good for 7 days, so you don't need up-to-the-minute earnings. However, be careful of your correction. The excess allocation (with earnings) should be moved to the 'suspense' account (EPCRS's term), and those funds can ONLY be used to offset the next Employers contribution. In fact, EPCRS says that no other ER contribution can be made until those funds are exhausted. I know circumstances often dictate that the funds are moved to the plan's "forfeiture" account for lack of a suspense account. But be careful not to use those funds for fees.

Furthermore, it does seem that if you fail both tests and you have fail-safe language in the doc, you must bring in people according to the formula until you pass the ratio test. No mention of the ABT otherwise.