BG5150

It obviously doesn't get rejected, because I see 3 years of filings without the Sponsor's telephone number. I just thought it was odd. I would think it would have to be on the SAAR though, and the SAR is developed using the info on the 5500...

Giving out the SAR today for the 2019 plan year. Who gets it? All current eligibles as of today and former ee's with a balance as of today? New participants in 2020 will get it. All current eligibles as of 12/31/19 and former ee's with a balance as of today? New participants in 2020 do not get it. As I understand it, former ee's with no account balance at the time of distribution of the SAR do not get it.

It's not a report. We fill in everything on the form and hit the 'Validate' button. The program then goes through its pre-determined checks and lets you know what's wrong, if anything. It doesn't tell you what's right, only errors (stuff that will make the filing fail) or warnings (stuff that will allow the filing to go through, but something you might want to just make sure of. One example is with our software, if a Schedule G is not attached ort indicated, and it's a large plan filer, we get a warning that we may want to include it. Or, if it is a former EZ filer that now has to file an SF, we have to say "first filing' that initial year and the program says, hold up buddy, are you sure you want to do this?)

Filings for 2016, 17 & 18 did not have the Sponsor's phone number entered. Client insists she wants it that way. 5500 software validates all the way without it. Is the phone # somehow optional?

I find it odd that child support would go to a retirement account. The money is ostensibly meant for the welfare of the children.

She made it before 12/31/19? Isn't it then just a 402g excess?

We have a plan that is receiving excess DB plan assets in the Profit Sharing plan. How do I show that on the 5500? Other contribution? Transfer in?

Oops. I missed that

Even if they could do that, they are still on the hook for the SH contribution.

We have out clients complete a "filing authorization" form every year when we, as TPA, are filing the 5500 on their behalf. Do we NEED to have one completed every year? Can we do just one that says Sponsor A authorizes TPA to file on behalf of Sponsor for all years until authorization is rescinded? I was also thinking that the authorization would be rescinded if the signer of the 5500 changes for any year. Is there a rule that you have to get one each year? Link?

I thought 415 corrections were under EPCRS, not the plan doc.

Thanks, Bill. I came to that conclusion after I posted this. I just may credit the regular employee with the $500 so the deduction is intact.

Have a client with a pooled 401k/PS plan. One owner had same earned income for 2018 and 2019. In 2018, they deposited the 415 max, let's say, $27,000 plus the full catch-up. In 2019, because the K! was identical, they deposited the max 401k and same PS as 2018 amount in August 2020. So, because the 401(k) limit went up $500 and with the same comp, she is over the 415 limit by $500. How does the 415 refund work when it's all deposited tot he trust after EOY? Do I just pull only the $500? I'm not gonna do a mid-term valuation for a $500 refund. I don't think I can just forfeit $500 of PS since 401k is the first 415 correction.

Are hours prorated, too, for contribution purposes? For example a 1,000 hour req'ment for PS?

If you have two plans and combined they are Top Heavy, make sure that the plan documents agree as to which plan gets the TH contribution.

It could work, but they don't need two plans. Just add 401(k) to the PSP. Structure it so that the participation have investment direction over deferrals and the ER had direction over ER funds.

Plan used to be hubby & wife pooled account. Then daughter joined the company in 2016. Plan was amended to participant-directed effective 1/1/16. Daughter opened her own account. However, the husband and wife contributed to utilize the pooled accounts (there were two, now there's three!). What kind of problems am I looking at with the pooled account for the parents, but an individual account for the daughter? (No other employees)

It's pretty much up to the participant which plan they take the refund from, no? Neither plan had any excess in and of itself.

Auditor is booking the ADP refund on the 2019 return and listing it as payable. So we will just offset 2020's distrib by that amount, I guess. Like I said in the other thread, I just do what they tell me to do, put the note int he file and move on to next year. Just was curious what others were thinking about it.

That was 5 years ago. I don't remember what I was doing 5 hours ago.

I'll take a look

This is from the Datair Plan Term Package participant notice:

Participant left employment July 2019 and is/was 60% vested. Employer terminating the plan on November 1, 2020. If this person takes a distribution next week, will they have to be 100% vested? From the IRS website: All affected participants become fully vested in their account balances on the date of the full or partial plan termination, regardless of the plan’s vesting schedule. (emphasis added) So, the date of the Plan Termination is after the date he is taking the distribution.

Do you book ADP refunds as a liability on the 5500? I have an auditor who insists on having the ADP refunds for 2019 booked as a payable on the 5500. I've never done this. What do you guys do?

Do you have a link to it?