BG5150

Side note: I know when you file an amended return at EBSA, it "overwrites" the previous one; at least the one that can be seen online. Does the DOL keep the original(s)?

Don't forget to mark it an an amended return...

In these cases, I just do what the auditor asks (after bringing up my concern), document the file for next year and move on.

I just had an auditor request this very thing.

I would proffer, in answer to # 2, that the employer gets a dedcution for those ineligible contributions, so they should stay as contributions in the Schedule H. #3 makes sense if #2 is followed.

This is a selection from one of our AAs: (note letter "e") a. As of the last day of the Plan Year in which the Plan Administrator distributes the Participant's entire vested interest. b. In the Plan Year in which the Participant's 5th consecutive Break in Service occurs. c. As of the Valuation Date coincident with or next following the Distribution Determination Date. (See Section G.4.) d. As of the earlier of the last day of the Plan Year in which the Plan Administrator distributes the Participant's entire vested interest, or the last day of the Plan Year of the 5th consecutive Break in Service. e. In the Plan Year in which the 1st Break in Service occurs. f. Forfeitures shall be allocated in the Plan Year following the Plan Year in which they are determined.

I think it's a plan document issue. I don't think you have to wait 5 yrs (or until the ppt takes a distribution).

You can do a QNEC enough to pass the test, if that amount is lower. But no way around no QNECs, I believe.

You can test on whatever compensation that is allwoed int he testing section of your plan documetn. Oftentimes, it'll be any comp that fits 414(s)

GG, April means that if more than 5% (or is it 10%?) of the assets are non-qualifying, you have to file a "regular" 5500 (with sched I for small plans) instead of the SF. However, with one-participant plans that can be filed on EZ, I don't think you would have to do the full fledged 5500 if the assets didn't qualify.

What if I "prepare" the forms, but when I send it to the sponsor for the first time, they decide to make changes to my numbers? After I make the changes, am I still the perparer?

From EPCRS: Notice the piece on deferrals mentions QNEC sepcifically, but the match piece does not.

Did the person roll the money over?

I thnk the crux of it is whether or not the person is performing services to the company.

Once a person is eligible for and enters the plan, then you look at the requirements to get an allocation. You will use the plan year as the basis. Not just the period eligible for the plan. Then if the person satisfies the conditions to receive an allocation, you look at the formula. So, in your case, it will be based on participation compensation only.

We've been using the 1984 UP life table in our calculations. (Well, in Relius) Given that many times most of the people I'm testing weren't even born by 1984, should we be using a more recent table? What you you guys use?

^^ I've seen MP plans go from, say, 3% to 0%. I see it like freezing the plan. However, I've never seen one at 0% from effective date. Maybe they could set up 1/2%, exclude HCEs, for the first year and amend it to zero the next.

What is the compnesation basis for the PS in the document? Full year or only while a participant. That will answer your question. The document knows all. (or at least most.)

unfortunately, I haven't seen any rhyme or reason as to when they deactivate them. I seen 4 or 5 years go by and they are gone, but I have had plans with 8, 9, 10 years no activity and the EIN is good as new.

Soemtimes in W2 runs, I've seen people in there twice. Are you sure this person wasn't listed twice?

Did you post the question? Did you ever get an answer?

I would go back to client and ask them.

No. It's just a matching contribution, subject to vesting, if applicable.

A payroll report will show you gross comp before any deductions, and that's what you want. With W2's, you often have to back into the correct number, the methodology depending on the state.

Right. yay. I got one right. Forward this thread to my boss!