BG5150

But what is the 2012 RMD basis? There was no balance on 12/31/11.

every day? time to move platforms?

Can't the sponsor set it up so the fees get billed to the employer and not the participants to avoid this?

So, if you start a business (or buy into a business) after the year you turn 70 1/2, you don't have to take an RMD because you weren't a 5% owner the year you turned 70.5?

Nope. (BTW, I'm studying for mine too. I highly recommend Derrin Watson's web seminar from Relius (Sungard/Corbel/whatever other company they are, too). I attended for Part I and it really helped focus on what I really needed to study for the test. The EOB delves into so many contingencies and arcana, that it's not the best study guide. The Part II webinar should be announced this week some time I believe.)

Our document provider wasn't too keen on doing that. By discriminating against one (or more HCE's) you were in turn discriminating in favor of the others who had no such restriction.

Would that matter?

1) you could have a match that was 20% on deferrals up to $10,000. Or 20% of deferrals, but nor more than $2,000 in match.

Did you remember to change the 11/30 payroll to $18k? maybe send a ticket to Relius. They usually get back to you in a couple hours.

Look no further than the plan document. It probably says rollovers can only be done by "participants" or current employees expected to become participants. Since the husband is neither a participant nor and employee, the plan precludes the rollover.

Well, you seem to know how much he deferred in December ($5,500?), so you could probably do it right now. I don't think you really need the comp. Just make sure 415 limit is NOT check in the contrib transaction. Otherwise it's going to tell you 415 is exceeded ($5,500 is greater than 100% of zero). I'd verify that with the client, though. (then tell them this would be a whole lot easier if they switched to calendar year! )

Again, how many payrolls do you have entered? In my experience, if you get the correct comp & deferrals into the correct payroll slots, the program will do a good job at making the proper adjustments. Is this the first year this is happening? We I get a new (to me) off-calendar plan, I try to recreate the past couple years on Relius. At least the prior year. Everyone gets at least two payrolls: a 12/31 payroll and a PYE payroll. This assures that the correct deferrals are being booked in the correct calendar years. When you run eligibility and the contribution transactions, the correct amounts will be entered on the Plan YTD screen. In your case, you would have: 12/31/11 5,500 11/30/12 18,860.48 (Don't forget to run a contribution transaction for each payroll date you entered. I made the mistake one time of just running one for the last day and wondered why everything wasn't there.)

How many payrolls are entered for this participant? You need at least two. One in December 2011 for his December comp and deferrals, and one sometime in 2012 with the Jan-Nov comp & deferrals. I'd probably use 11/30. This way the proper deferrals get booked for the proper year. And, year over year, you'll be able to match W2 #'s to Relius as a double check.

Pardon my ignorance on the matter, but what are the liquidity concerns of OTC offerings?

As long as it was corrected w/in two years, I'd say it was eligible for self-correction. But part of SCP is that you have to come up with and institute changes that would prevent the error form occurring again.

You can lead a horse to water... If they have the SH match, then at least the people who want to save are rewarded. And the two HCEs will be okay deferring the max. Has the financial adviser been out there to pitch the plan? Are the assets with a big carrier? Sometimes they can send out a crew to rally the troops.

Forfeit the excess w/ earnings? Money to be used to offset future contributions (not to pay fees).

Are you over 59 1/2 years old? The plan may allow for a distribution if you are older than that.

Whose fault was it?

And the regs say the "Employee need not take counterproductive actions" before taking the hardship, as it may increase the need. Unfortunately, the regs only give us the one example: a person doesn't have to take a loan first if the existence of that loan would preclude the issuance of a mortgage. I see that as a bona fide reason. But that's the only example they give. They don't have an example of someone who needs $10,000 to pay for college. I don't see where a loan in that case would 1) increase the need or 2) be a counterproductive action. Yet, it seems in practice, a lot of people just "say" the loan would add to the need and just issue the hardship with no loan.

I see no rhyme nor reason to when the "View New Posts" link works again after the first time. At the moment, for the time being, right know, as we speak, it's working for me. That is not to say there won't be a sunspot or an earthquake in Outer Mongolia in an hour that will make it stop working again.

You can use Form W4-P for that.

Custom Language, I'm assuming. FT William handles it nicely.

These are the break in service rules for rehires: One year BIS (“hold-out”) rule: once EE incurs a one year BIS, plan can disregard EE’s prior service unless and until EE completes a YOS measured by reference to re-employment date; then retroactively count prior service. Parity BIS rule: if EE (1) is plan participant; (2) is 0% vested; (3) incurs 5 consecutive BIS, plan permanently may disregard EE’s prior service.

Whether you keep out p/t rehires or "hygienists," you'd still have a coverage problem, no?