BG5150

EA?

Still, for those under $200, I'd just send them a check with a letter saying you have 60 days to roll this over or it's going to be taxed. That will save time and effort of having to send out forms, waiting for nothing to come back and then send out the checks.

If it's under $200, could you put it into the trust and then just have the custodian send out the proceeds? No withholding to make up if they want to put it into an IRA.

The match basis is capped at 6%, or $15,000 in your case. The match allocation is 150% of that which is $22.5k.

So, I'd have to tell my accountant that the $100,000 I reserved for PS is deductible for 2013, but we had to do an 11-g that added $2,400 and is deductible only for 2014? So when he sees the check for $102,400 he'll have to remember that not all of can be deducted?

What year's W2 will it be on?

From Treas. Reg.§1.401(k)-1(d)(3)(iv)(E)(1)

You need to make sure you have the correct eligibility set in the SOURCE, not on the general eligibility tab. In version 18, it's the Source Overrides tab (3) when you open up the specific source.

It's somewhere in the financial need test. Treas. Reg.§1.401(k)-1(d)(3)(iv)(E)(1)

Was it for a ton of money? Is it putting the person in another tax bracket?

A few answers for you (in no particular order) Hardships are not eligible for rollover, therefore withholding is optional, and 10% must be taken absent a contrary election. Check the plan document to see if a partial in-service withdrawal maybe done. If it must be a full withdrawal, there probably is no provision that it all has to be a rollover or all has to be taken in cash. The participant can take the expenses in cash and roll the rest over. Over 59 1/2, both distributions are taxed as ordinary income. 20% w/h on in-service and optional (10% standard) on h'ships. How can someone afford the taxes on a hardship if no w/h is done? It's one thing the participant must take into account before they take the distribution. Budgeting for medical expenses is an unfortunate necessity for many Americans. Does this person have access to a medical FSA at work? Perhaps they could divert a little income a month to that account. It's like tax-free medical care.

They can't issue a corrected 1099-R if the participant returns the money? Who's fault was the second RMD? Participant, administrator, carrier?

On the actual EZ form it says that it is "open for public inspection." How does the general public go about seeing the EZ forms?

He does not have to take the RMD. However, if he retires later in the year, he has an impermissible contribution to his IRA and the trust should issue 2 1099's--one for the rollover and one for the RMD.

And maybe find a provider that will keep track of that stuff? Or is it standard practice not to track it at all?

To me, it's not zero deferrals, it's the null set, as there is no opportunity to defer. There simply is no denominator. I look at it this way: Will the IRS take a second look if you took the person out of the test? Probably not. Will they take a second look with an all zeros test? Maybe. Do I want to take that chance? Do I leave it up to the Client? To be honest, I've done it both ways, under client direction.

Is the participant clamoring for this money? Why not just leave it alone?

I would say not in 410 at all either. Not just not benefiting, but excluded altogether.

I think the EOB recommends keeping him out, but don't quote me on that.

The 2013 ADP test (in this case) is run with the 2012 NHCE numbers. The "new" company wasn't in the plan in 2012, so those people aren't in the test. Their 2013 figures will be in the 2014 test.

Well, the EGTRRA restatement didn't take affect until 2008 at the earliest. In 2007, the GUST doc was in effect.

Whose job is it to monitor the YTD total? What if you switch jobs? At $20 a pay, it would seem tough to keep track all the time.

They can, but you have to provide a paper copy if they ask for it.

5500 is due 7 months after the end of the month when assets were distributed, so I would use that date. Is there any place else you would use that date?

So, even though this is aimed at people not covered my an employer plan, it's still incumbent upon the employer to participate in the program.