BG5150

Why would it become an IDP?

:rimshot:

Use Schedule H, tax due under Section 4979. Amount involved is BEFORE allocable income.

Yep

Participant has money in 401(k), Safe Harbor, Profit Sharing and funds transferred from a money purchase plan. Trying to figure out maximum hardship availability. Can the MP Transfer money be taken? I know MP transfers retain the J&S provisions. But can they be taken for hardships?

Plan has $20,000 in forfeitures and the plan calls for them to be reallocated or used for fees (not allowed to offset ER contrib). I do my work for the year, send them a letter saying this is how you reallocate the $20k. I also include my invoice for, say $2,500 (made-up number). Should I have only sent a schedule that reallocated $17,500?

So, the sponsor can't pay the fees? It has to come out of forfs?

Most everything is taxable int he year of distribution now except 402(g) before April, right?

Then why ask it again?

I would say just reissue the check and move on if there is ample evidence the funds were sold prior to March 15. I look at it this way: what if someone took a distribution on December 27, 2012 check issued December 28, 2012. The 1099 will say 2012. If the check gets lost and not reissued until February, the 1099 will still say 2012 even though the check that eventually gets cashed is dated and executed in 2013.

Anyone over 70 1/2 who has "retired" must take an RMD. 5% owner or not.

They don't even HAVE to withhold if the person doesn't want it.

Wait. Just re-read the OP. It says "an employee non 5% owner)". Is this person still with the company? If so, I think they CAN roll the money to an IRA w/out the RMD, because, as yet, none is due. (from the plan)

My take on it is that an RMD is due from the plan before the RBD for year a participant retires. Period. Qualified plans cannot be aggregated like IRAs for RMD purposes. So a person can't simply roll the proceeds to an IRA and move the RMD out of there.

From the EFAST2 FAQ:

I think if you try to file electronically without the opinion attached it will reject. What do TIAA distribution forms have to do with filing a 5500?

Well, are they saying the loans (MUST, SHOULD, COULD) be reamortized? The word chosen is very important.

And that's something the new r/k would have nothing to do with.

1) Plan must allow for it. 2) Participant must ask for it. 3) It can't run afoul of the reamortization rules. What does the new r/k mean by unilaterally reamortizing the loans? Giving people more money? Make up for lost payments? Extend all loans out to 5 years?

^^ And continue to be an asset int he plan until offset.

I think the loan should have been defaulted at the end of the quarter following the quarter in which first loan loan payment was missed. Period. Any loan corrections or modifications you want to do should be done under VCP, I believe.

C'mon, Bird! You're slackin'!

In General Instructions for Certain Information Returns

Enhanced SH Match can be as high as you want it for ADP purposes. Any SH match on deferrals over 6% does not satisfy ACP SH. (That doesn't answer your question, but I thought it was worth mentioning.)

Reminder: And their balances are removed from the numerator AND denominator for top heavy calcs.