BG5150

If you use one, what type of workflow tracking software do you use to manage your firm's caseload? Pension Pro? Pension Pal? Other software? In-house database/spreadsheet? We are looking to alternatives to what we do now. I've used Pension Pro, and it may be too robust for us. I'm not sure if there is a scaled-down version, but at the one company I worked for that used it, it seemed a bit complicated with all the task assigning and stuff...

Seems like deferrals are already effective in the plan. I thought for plans like that, SH had to be for the entire year. And for plans with no deferrals yet, you can add a SH, but it has to be for at least 3 months.

Too late for 2020...

Plan is termed a/o 9/30. In process of paying out accounts. Hope to get this done by 12/31 for obvious reasons. Tracking down former employees, get in touch with one of them. She tells me she is getting a divorce. Normally, flag goes up, put hold on account and wait for DRO. Is that the same thing here? Can a divorce hold up a plan termination? Or, at least, hold it up for this one person?

I had a brain fart. I was just discussing with a co-worker about a client who is an employee of a company and he has his own plan (un-related). So he has two 415 limits.

Doesn't each plan have its own 415 limit?

Also, what happened in the years before? You have to start at the beginning. You track sets of deferrals (Jan to Sep and Oct to Dec) and just draw a chart showing where the deferrals overlap between calendar and plan years.

I'm not saying you are correct, BUT if the $4,755 is 2019's catch-up, then there is a way to treat it that way in your record keeping software. There is probably a field where you can enter various years' catch-ups. Talk to their support.

I wouldn't be comfortable paying any benefits other than by check unless the participant consented. I think the best way to do this is the way someone mentioned: Hey, pal, you already paid taxes, or you will if you did not include that 1099-R in your tax return. So you might as well cash the stinkin' thing.

Is it a safe harbor plan?

Keep an eye out for coverage, too.

Are you allowed to do that without express written consent from Major League Baseball? Or, rather, the participant?

Semi-educated guess: the Employer is using the vendor to produce and disseminate the SPD and QACA Notices, etc from the payroll files. So, if the vendor doesn't know about these people right away, ie DOH, then the Notice won't be given timely. I worked at a place like that, and we 'required' the plans to have at least monthly entry dates (for immediate on hire eligibility) for just that reason. 'Require' is in quotes because we knew we could not mandate that, it's just that we could not record-keep that plan and uphold our end of the 316 services we provided.

So the rules are the same for a MEP with 5 adopters with 25 participants each? They re all on the large plan schedule with no safe harbor?

Looks like you have to at least give the 402(f) Notice. But, it says the PA won't fail the requirement if the Notice comes back undeliverable. And it seems like the force out can happen. Isn't that at odds with the lost participant rules that say you have to try other means to locate them? Or is that just for the folks over $5,000?

Plan calls for mandatory distributions under $5,000. It says it will be done without participant consent. Do they have to send out distribution forms to those they want to force out first? If so, what is the cite?

On reading the instructions again, it seems as though we ahve until March 2021 to file and pay the tax.

Plan failed 2019 ADP test. Refunds are being done now. What 5330 would i use? I figured 2019. However, is the form considered late (calendar year plan--it's even past the extension date)?

No problem at all. They are two completely different contribution types. Just be cognizant that the safe harbor MUST be trued up at EOY.

I think we are going to consider the income earned on 12/31. So no income for short plan year ending 10/31. It's ok, b/c owner did not make deferrals and probably doesn't want to fund his own safe harbor--keep costs to a minimum.

I wouldn't think there would be two forms. Maybe this is a SEP IRA or something? Ble_Sky: Is there more than $250,000 in the "plan(s)" combined?

A plan document will be more than just a form or two.

How do you calculate the owner's comp in a short plan year? Doctor gets Schedule C, but is terminating Safe Harbor plan on 10/31 and wants to close up the small plan before EOY 2020.. How is her compensation calculated? Is it zero b/c it's not determined until 12/31? Or do they have to wait until next year and take 5/6 of the net income?

Do you have a written plan document? If so, who did that for you? Talk to them. If not, then you don't have one or two plans. You have NONE.

I find it odd that the coverage test would apply to a contribution that is mandated in the code. The only people being left out are the people the code says doesn't have to get anything to begin with.