BG5150

Who's Bill?

What does the plan say?

The IRA shouldn't issue a 1099-R for that as it is a return of an ineligible contribution. The Plan will issue 2 1099's--one for the rollover and one for the excess. The IRA shouldn't be involved in the 1099s at all. However, everyone must pay attention in this. The plan will just be issuing the refund 1099-R for the excess and earnings gained (or lost) whilst in the plan. (Maybe) the IRA custodian issues a 1099-R for the gains on the refund? Or do the tell the plan and the plan will issue the refund 1099-R including plan and IRA earnings? I do not like the latter, becasue then 1099-R's don't match up to distributions from the account. And if there is a loss at the IRA, they need to tell the plan so it can issue the correct 1099-R? Again, you have a problem with the 1099's not matching distributions. Can you even do a negative 1099?

7 come 11...

Is the new table out? Where can I get it?

Not asking for you guys to do my work, but is there something in the EOB that outlines the calculation with the permitted disparity?

I stand corrected.

ASPPA is giving me the runaround. Iasked them this questions twice and no one has returned my e-mail. My co-worker took the practice test for the QKA1 exam. How can he see the question-by-question results? All he can see is the overall score. If that is not available, how will he know in which topics he is proficient and which he is deficient?

So who issues the 1099-R for the earnings? If that $5,000 is now worth $5,250, the former participant is getting cash totaling $5,250, but is only getting a 1099-R for $5,000. What if the account lost value? Say it's worth $4,750 now. Do you issue an amended 1099-R for $4,750?

I thought the RMD for the year of death is taxable to the participant. Anti-assignment prevents me from paying it elsewhere. Just was checking to see if we could pay it to the estate. I guess it wouldn't matter if we paid it tot he particiapnt; whoever has signing authority on behalf of her trust can cash the check.

Participant, former employee, died this year. She was taking RMDs. Can the 2021 RMD check be made payable to the estate?

"Portal." You mean portal. I hope.

Yeah. This should be fine.

I have the formula to calculate a 'regular' EBAR. That is, not including permitted disparity. Where can I find the formula for the permitted disparity? Does anyone have excel formulae to calculate either the EBAR given the contribution, or the contribution given the EBAR?

I don't think so either. Those funds didn't belong to anyone, everyone in the DB was fully funded. Therefore, there is no spouse to attached those funds to.

Is it an option do that in your document software?

That's very interesting. My 5500 software does not have the SAR/AFN feature if the filing is an EZ.

Catchups are excluded. So, where does it say that if my earned income is $19,500 I cannot put in $26,000 including catch-up. Assuming no other contributions, my 415 comp is $19,500 and my annual additions under 415 are $19,500. I haven't violated 402(g) as that is merely a dollar figure. (Not that I would allow this, but now I'm curious as to what reg is involved.)

402(g) is merely the dollar cap. Isn't there a code section that also caps it at 100% of income?

What is the penalty for filing a 5500-SF instead of an EZ for a one-participant plan? Is anyone really going to care?

Have an S-corp client. Father owns 100% of company. Daughter only employee covered. Can they file an EZ? Does attribution count for this?

I'm not sure what you mean by the bolded. The only people who must get at least a gateway are those who are getting a 401(a) contribution. Match does not count. So unless the plan is top heavy, that person doesn't HAVE to get something if they are in a class that is receiving zero PS. However, if the sponsor wants to give them something, then they will ahve to get at least the gateway. Any nonelective 401(a) contribution (except a QNEC) is subject to the plan's vesting schedule for that money type. Remember, if the sponsor makes a PS, they lose the TH pass due to the SHMAC. If the plan is TH and that person must get the TH contrib, but doesn't meet the criteria for a PS, they still must get the gateway.

I don't think the last day of the plan year matters much if it's w/in a couple days. I always just use the end of the month that the last withdrawals happened. Again, I like the round numbers.

Then why are there two lines if only one is needed? It seems the administrator MUST sign the form. The Sponsor is optional then? If the Administrator and Sponsor are different people, do they both have to sign? What if they are different people and ONLY the Sponsor wants to file? The edit checks in the EFAST system will reject a filing if only the Sponsor signature is present.

What if the snail-mail comes back as undeliverable? Does the Plan Administrator have to follow the lost participant rubric to get them SPDs and SARs? Does anyone really do that? Side note: what about participant statements? They must be furnished with at least one per year. I know some custodians will just turn off mailing the statement if it comes back as undeliverable. Should it not fall to the plan administrator to try and find these people?