BG5150

If the plan terminated in 1989, why were there subsequent TPAs? Were the assets not all distributed?

Aaaaaaaaahhhhhhhhhh! ?????

This. You could've filed 10 years worth of EZ's with a balance of $40,000 then just stop. However, be prepared for the letter from the IRS. But, you just answer back: I didn't file b/c I didn't have to. The only EZ under $250,000 you must file is the Final one, if I'm not mistaken.

I don't know why I'm blanking on this, but we have a client where the only active "employees" are the husband and wife owners. There is one former employee who still has an account. Is this considered a 1-participant plan? MY gut says no, because I would think that the existence of that third account would require bonding of some sort.

Without asking you to do my work for me, do you think that would be in the BPD or the AA?

My only question is: does the 500 hour rule get prorated to 250? It's important in that we have someone who terminated with 450 hours. The ER has limited discretion in that she can do an 11-g amendment to add people if she wants. Other than that the contribution is defined by the plan doc.

I would call the SSA and ask them how an alien can obtain a TIN for work purposes now that the offices are closed.

So the kid isn't able to participate unless they hire someone else under age 21? I would think it would be discriminatory if the reduced the age for 2020 and reinstated age 21 next year.

Short plan year 2020. Plan terminated 6/30/20. ER wants to do PS. Has last day/500 hr rule. Does that 500 hr threshold get prorated to 250?

The EOB Compensation grid says NQ Plan Distributions are included in W2 and Withholding Wages, but NOT 415 (and simplified 415) comp, unless the plan says otherwise.

In any case, I would get a written statement from an attorney that this isn't a prohibited transaction before you go ahead and do it.

Plan doc excludes rollovers when determining the cashout balance. Participant has $550 PS (100% vested) and $45,000 Rollover. Because R/O is excluded, this participant is a candidate to be cashed out. Does the trustee just cash out the entire account and withhold $9,100? Or do they roll over the balance to an IRA? (The plan's threshold for IRA rollovers is $1,000)

It would be a controlled group, so the 415 limit applies across both plans.

If you have no HCE eligible for deferral but not for SH, then you pass the ADP test for that group automatically.

I don't see how the ADP test is failing (so badly). You would run the ADP test for the people who are not fully covered by the SH, you don't have to run an ADP test for the whole plan. The people who defer and cannot get a SH will almost be eligible to be tested separately. And unless you have a bunch of newly-hired HCE owners or family, that otherwise excludable group will pass. If you have an owner HCE, then hopefully it won't fail that badly.

I disagree, Bill. It says 1,000 hours in one Year Eligibility Service Period. That period likely ends on the 1 year anniversary (or really the day before) of employment. So, for both of the examples, the one Year period ends in 2020.

I would contact the attorney who drafted the document.

I'm good on the correction, I think. Just wanted to make sure I didn't miss anything with my meanderings through EPCRS, and if there was really anything in 6.06(3) that I needed instead of 6.06(4).

He will know his 2021 RMD on January 1, 2021 because the RMD is based on the 12/31/2020 balance. He can ask T Rowe Price for an RMD in the amount of (2021 RMD - total amount monthly payments).

DC plan paid someone out at 100% vested when they should have been only 20%. About an $8,000 difference. So start in EPCRS, Appendix B, Section 2, part .05 Correction of Other Overpayment Failures section 2.04(2)(a)(iii) But, 6.06(3) is Correction of Overpayment (defined benefit plans). Shouldn't I be using 6.06(4), Correction of Overpayment (defined contribution plans and 403(b) Plans.)?

It might not be a 415 failure. Just annual additions for 2020. It may curtail the 2020 employer contribution if there are those at or near the 415 limit.

If the contribution goes in now, it will be considered 415 annual additions for 2020.

Is the auditor insisting the sponsor pay the excise taxes, too?

I know I'm fighting a losing battle. I like these little mental exercises from time to time.

Forgot about the tresury regs.