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Everything posted by BG5150
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FWIW, Relius Administration uses 3% as its threshold before it issues a warning that the formula might be discriminatory.
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I have a followup question: When prorating, is it any part of the month counts? Full month? Fifteen (15) days? Relius Administration seems to round up and down around the 15th. For example, if the last day is August 9th, then the proration is 7/12. But if it's August 18 then, then it's 8/12. The reg (1.401(a)17-1(b)(3)(iii)) just says "months."
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Private Search Fees deducted from participant account?
BG5150 replied to Dennis Povloski's topic in 401(k) Plans
Doesn't the IRS have a minimum number of letters that need to be sent? Like 50? Or 75? Plus, you never know if the letter got to the intended person or not. You are not appraised to undeliverable pieces. Not are you appraised of what address they have for the people. -
On paying back the loan: If he pays back the entire amount now, he is locked out of a loan for a year, but will have the full $50,000 available then. However, if he repays it according to the schedule, in TWO years from now, his loan availability will only be about $10,000 (he'll have $40,000 outstanding a year from now). Just something to consider.
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If it's positive income on the way back in, it's probably negative income on the way out. (That's if the income line is where it was supposed to go in the first place.)
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I think the '08 material is still valid
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That is more data verification than testing. For calendar year plans, I can just look at my data to see if anyone went over 402(g). And some (usually) simple spreadsheet calculations will show me if the match is off. Although, you can run the data through the ADP/ACP testing program to catch failures easier.
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Determining Policy Loan Limit
BG5150 replied to retbenser's topic in Distributions and Loans, Other than QDROs
I always did: Lesser of Test 1: 50,000 - highest outstanding loan balance in past 12 mos* Test 2: 1/2 vested account balance (including outstanding loan at time of calculation)** - outstanding loan balance *--in OP, if 10,000 is current outstanding balance and the loan has been in place for some time, the highest balance in the past year is bound to be higher **--capped at 50,000 -
Want to make ineligible a department tha is now eligilbe
BG5150 replied to Jim Chad's topic in 401(k) Plans
And none of them have an account balance (from TH or SH)? -
That was my initial thought: "All the safe harbor reasons as of today, plus any more they throw at us in the future."
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The checks should have a bank name and account number on them. Contact the bank.
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even simpler algebra problem
BG5150 replied to Santo Gold's topic in Humor, Inspiration, Miscellaneous
I wouldn't say that 0x is wrong, although it's not the way we usually expect to see it. It's like having 12 apples from which you take 12 apples, so you are left with 0 apples. Of course, having zero apples is about the same as having zero solar systems or zero x's. They all equal 0. But in this case, "x" isn't a label such as inches or apples or solar systems. It ostensibly stands for an unknown quantity. In the case of the original problem, "x" is undefined. -
Could you do no P/S but make a QNEC? Usually there is a last day rule for that. However, this year's contribution would be 100% vested.
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Curious about the bogus posts
BG5150 replied to Bird's topic in Using the Message Boards (a.k.a. Forums)
All he needed was to have some links to a wedding dress site. -
Is it a traditional IRA (as opposed to a conduit IRA)? If so, does the plan allow for rollovers in of traditional IRAs?
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I didn't think the match could go higher as the deferrals went up, just lower. I've been wrong before.
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I have a deceased participant whose beneficiary is not a US citizen, nor does she (the beneficiary) have a US taxpayer id. How do I go about paying her out? Do we have her fill out a W-8BEN along with the regular plan paperwork and that's it? Do I have to do some research on the tax treaty between US & Poland?
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Bird, it comes from EPCRS (Sec. 6.06(3)): (bold and spacing are my emphasis)
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Is the son a 5% owner? If so, I would say yes, becasue she would we an owner, too, by attribution.
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The amendment was the Heart/WRERA, so it wasn't discretionary. The doc says that forfs can be used to pay for plan expenses. I don't see where it says the money cannot revert to the Employer for expenses already paid. The plan is the Corbel Volume Submitter.
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Basically, someone paid our retainer back in December from company assets. In doing the 2010 analysis, I mentioned there's some forfeiture money. He wants to know if he can pay get paid back for that. Also, we did an amendment in December which he paid for from the company. Can that be reimbursed? All the invocies we are talking about are int he 4th quarter 2010. And would be paid from the forfeiture balance a/o 12/31/10.
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As for the contracted employees: as long as you have a definitely definable class of people you want to exclude you can, as long as you are passing your coverage tests.
