BG5150

Didn't the CRDs expire? Why put an end date?

Sure. You had participants, I'd guess. So file it with all zeroes except the participant account.

Hardships are for immediate and heavy financial need. The former does not apply.

No deduction yet. For 2020. Taxes not filed.

I figured. Just grasping...

In 2020, ER deposited $100,000 to a holding account in the plan (I know!). Maxing out the owner and giving 5% to the EEs results in a $70,000 allocation for 2020 and passing of tests. Does he have to allocate the remainder to the participants? Or can he take back the funds as a Mistake of Fact?

Based on the letter of the law, assuming the plan uses the safe harbor rules, I'd say no. She is not purchasing a principal residence. Nor are moving expenses listed. Does the employer not provide moving expenses?

Thanks for that!

We had an issue with Relius that some plans that had already been filed got "Republished" after we ran the 5558 batch. Emails went out to the the clients saying they were republished. I got a bunch of calls & emails, and I told them not to worry about it. I checked and the originally filed forms were indeed on EFAST. However, I think this was one client who just got the e-mail and just re-filed. Oddly enough, there are two filings on EFAST right now; one on the original date and another for yesterday. Not sure what I should do.

Prior to the end of the tax year...

I just got the same thing, Lou. Do you use Relius for your 5500's? Though the message I got was not for an EZ. 'Twas an SF.

$1,500 for two or more plan years, no?

If he's paid $350k in 2021, how is he not an HCE for '22?

Has the comp limit ever gone up more than $5,000 in a year? Going back to 2008 it went up $15k to 2009 from $230 to $245. All other years since then it was $5k increases (with a few years of staying the same)

I don't mind all the questions. It just bugs me you are a Mets fan.

Plus earnings.

"Retirement" in a plan is severance of employment on or after Normal Retirement Age.

If a plan has a balance in the forfeiture account after the fees are paid, the remainder should either supplement an employer contribution or be reallocated as an Employer contribution. The Employer may not be making a Profit Sharing this year, but they could always "declare" one in the amount of the forfeitures to be used. Even if to pay expenses is the only thing checked int he adoption agreement, the remainder should still be reallocated. This is from the Datair Basic Plan Doc we use: [quote]Unless otherwise elected in the Adoption Agreement, the Plan Administrator shall allocate such Forfeiture in the same manner as a contribution by the Employer for the year in which said Forfeiture occurred. For each Plan Year that Forfeitures are allocated, the Plan Administrator shall designate the specific Employer Contribution or Contributions that the Forfeitures reduce or supplement. The Employer may elect in the Adoption Agreement to use Forfeitures to offset administrative expenses of the Plan to the extent the expenses are Plan expenses and not settlor expenses and any remaining Forfeitures shall be allocated in the same manner as a contribution by the Employer for the year in which said Forfeiture occurred. Forfeitures that are used to supplement a contribution will increase that contribution that was otherwise specified for the Plan Year. Forfeitures that are used to reduce a fixed required contribution reduce the amount that the Employer would otherwise have to contribute to the Plan for the Plan Year.[/quote]

Dave, you only have 176 posts to go to be a Senior Contributor!

If you have been the TPA for this plan for a while, you may want to ask yourself ('you' meaning your firm), why haven't the plan's forfeitures been timely allocated in the past? They are supposed to be used every year.

Peter, do you think anyone would get in trouble if they report $500k bond when it was actually $2MM?

Plan has the standard force-out of terminated participants option: under $1,000 cashout, and under $5,000 roll to an IRA. Plan is ongoing, not terminating. If the plan administrator cannot locate someone with less than $1,000 can they roll the money to an IRA and let the new custodian work it out? This is assuming the PA has satisfied her due diligence by sending mail to last known address and subsequently sent mail to a more recent address obtained via commercial means. All attempts resulted in returned mail. What happens is the mail is not returned, but the PA has reason to believe the participant is not at any of the addresses available through commercial investigation? I guess the people living there now are just throwing away any correspondence to the participant at that address.

It's yours

"When in doubt, max them out." (with the vesting) I just made that up just now.

FWIW: I just put the actual bond amount.