BG5150

The instructions for Schedule SSA indicate that for the participant's balance in 4(h) should be the value at 'time of separation'. Does anyone really put that value in there? Or do you put the balance at the end of the reporting period? Or even just a current vested balance? Does it matter? Your thoughts are appreciated...

Was the old plan officially terminated? Were the assets liquidated? Does that matter?

Just make sure none of the HCE's are getting more reimbursement than they paid out. I'm sure the DOL would have something to say about that.

Check the docs first to see if you can do this, first. You may have to amend them if a QNEC is not allowed (or, rather, not chosen as an option by the employer).

I think FreeErisa only has filings thru 2004 plan years. I'm not sure of the other site.

BINGO!

Is the 5-year "widow" mandatory? I seem to remember that there is a provision to apply to the IRS to switch before the 5-yr period is up. And, if it's a prototype, doesn't the plan doc specify what method is used? (Bear with me, I've been out of the business for a year and a half, and I'm just getting back into it, so a lot of stuff has slipped my mind...)

This may be semantics, but you don't have to worry about him when doing the testing IN 2006 for the 2005 plan year. However, testing FOR 2006 (done in 2007, most likely) he will count if, in fact, he is eligible for the plan. He will NOT be an HCE because he has no compensation in the lookback year. Ne c'est pas? (Am I not correct?)

I would say check the compensation definition in the plan docs.