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BG5150

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Everything posted by BG5150

  1. BG5150
    That's more of a sentence than a penance.
  2. BG5150
    My very first post about coverage and testing was based on the OP. Didn't realize the premise had changed.
  3. BG5150
    But now I see he said this. Conflicting info. Or did he really mean the non-CEO HCE would get 0%?
  4. BG5150
    This is what I was basing my comments on.
  5. BG5150
    I would think they enter right away. They have 1 YOS? Check. They turned 21? Check. Entry date has come and gone? Check. Participant on rehire.
  6. BG5150
    Give them Code C in the new plan and D in the old plan. Code C Use this code for a participant previously reported under the plan of a different plan sponsor and who will now be receiving a future benefit from the plan reported on this form. Also, complete columns (b), (c), (h), and (i). Code D Use this code for a participant previously reported under the plan number shown on this form who is no longer entitled to those deferred vested benefits. This includes a participant who has begun receiving benefits, has received a lump-sum payout, or has been transferred to another plan (for example, in the case of a plan termination). Also, complete columns (b) and (c). Participants should not be reported under Code D merely because they return to the service of the plan sponsor.
  7. BG5150
    Obligatory: What does the document say?
  8. BG5150
    If group C is more than 30% of the NHCE and they get nothing, and they otherwise satisfy the conditions to receive a PS, then you fail coverage. Note: remember these groups are artificial constructions. Everyone is considered separately, you so can give everyone a different rate as long as you are passing the testing. And don't forget you still have to pass nondisrimination testing. If the owner is a lot younger than a bunch of the staff, it'll be difficult to pass the test with palatable contributions to the NHCE.
  9. BG5150
    If this isn't a SH Nonelective plan, the poorly performing people do not need to get anything at all. As long as you are passing coverage and nondiscriminaiton testing.
  10. BG5150
    Not unless officially adopted, right?
  11. BG5150
    You said what I was thinking. LOL
  12. BG5150
    But how many NHCE really defer at such a rate?
  13. BG5150
    Just make sure there is no Fail Safe language elected. If so, you must address coverage per the rubric stated there.
  14. BG5150
    Thanks!
  15. BG5150
    I was looking over some correspondence that a national carrier put together for sponsors to send HCEs before they get ADP refunds. One of the blurbs says that Roth excess contributions are not taxable, and pre-tax contributions are taxable. But it also says that the earnings on BOTH Roth and pre-tax contributions are always taxable. Is that true? Even if the Roth account is eligible for a qualified distribution (ie the 5-yr rule was satisfied)?
  16. BG5150
    I don't see a point in setting the auto enroll percentage too high. If I ignored the correspondence and all of a sudden had 10% taken out of my pay I might be like "heck with that, stop it right now." But if only 3% came out, I might be like "Hmmm, that wasn't too bad..."
  17. BG5150
    5500-SF or 5500 w/ Schedule I, depending on the nature of the assets.
  18. BG5150
    There's not much of a difference between the two. Hopefully the type of informational report you make to the DOL is not a determining factor as to whether you become an S-Corp or not.
  19. BG5150
    I would be hesitant to craft such correspondence. For a couple of reasons: 1) Once it's out there, you have to maintain it with the current rules and regs. 2) What if you forget or omit something? What's worse: giving bad info or incomplete info? Well, the former is worse, but the latter isn't much better.
  20. BG5150
    I agree with Luke. At least there is a paper trail showing the initial refund. And in this case, I would include gap earnings in the distribution just because it's been a year since it was supposed to have been distributed.
  21. BG5150
    I would suggest even though someone becomes a participant on the day they satisfy the eligibility requirements, their actual entry date is the first pay date after that.
  22. BG5150
    Was that language a standard part of the plan, or was that added in? Like Bird said, that setup smacks of a CODA. What's to say the ER and the EE aren't striking a deal with an HCE to limit her compensation to zero so she can get those funds just paid to her now as salary. For example, she could have a choice of getting paid $200,000 and $10,000 into the MPP (5%) or just "limit" her MPP comp to zero for the year and get paid $220,000.
  23. BG5150
    Did that plan get a determination letter?
  24. BG5150
    That's for loans.
  25. BG5150
    You would not be able to carry a 2020 deposit over for a 2021 contribution.
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