BG5150

If no HCEs benefit, coverage passes automatically, no?

It's actually tests, plural. As a CPC, you should have a good foundation. There is no study guide like for the ASPPA tests, just a syllabus. I took Derrin Watson's webinar (from Relius) for both tests and they were invaluable. Best thing to do, maybe download the sample tests and see how you do.

Has anyone seen or heard of the IRS coming down on this stuff in an audit?

An ERPA will allow you to talk to the IRS on behalf of your client. Mere PoA doesn't work.

FWIW, I'd do #2.

One thing missing from that is: If the plan is utilizing a SH Match, AND the calculation is per payroll, the match for any particular quarter must be sent to the trust no later than the end of the quarter following. From 1.401(k)-3©(5)(ii)

Example: Terminated Employee's account is worth $10,000, the Trustee sends him a check for $12,000. Example: ADP refund is 600, person is paid 900.

Just curious: what kind of accounts were these? Are they with a big carrier? Individual brokerage accounts? Someone should have notified the custodian that the accounts should receive contributions any more.

If you are worried about '14, switch to current year testing. And you CAN do a QNEC for a prior year test, but you have to wait until 12 months after the PYE to do so, (I'm not sure if bottom-up is allowed in that case, though. Take a look at EPCRS)

You also need to document procedures that will prevent this from happening again.

Does CEEBS have anything?

It's 10e.

Note, it says "exclude ALL Participants." (my emphasis)

Profit Sharing plan's trust is in a pooled account. Balance forward valuation. Plan Sponsor now wants to take plan expenses from the trust. The expenses are justified and eligible to be paid from the assets. What kind of notification (if any) is due to the participants?

It's official! You can all call me the Grand Poohbah of Pension Consulting now. Or, BG. Your choice.

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?