BG5150

What if no one has reached 50 year? Can we remove that feature without worrying about anti-cutback rules.

Can you offer in-service withdrawals at age 50 of Profit Sharing money? Does it HAVE to have a seasoning component? I seem to remember a 2-year rule. Or is it if you have a seasoning rule, it cannot be less than 2?

Did you call Relius?

That why all your plans should be on a daily valued platform.

Larry, an antidote to the "little RMDs" from the 401(k) Plan is to make the contributions during the year and take an in-service rollover withdrawal toward the end of the year. Therefore, there is no 12/31 balance to trigger an RMD from the plan.

Are you sure they were completed properly?

I don't think he ADP failure figures into this. The correction is in EPCRS. The money gets removed (not forfeited) from the account and placed in a suspense account. The funds in the expense account are to be used to offset future employer contributions. In fact, no ER contributions are allowed to be contributed until those funds are exhausted. The amount removed from the account should be adjusted for earnings.

You can just wait until 2020 and do an 11-g amendment to give allocations to whomever you want to make the tests pass.

Larry, a few old things in there that we don't need to be worried about any more. (S-corp officers and TLAs) Do you still think participant directed accounts are "nonsense"?

I find that to be an odd request as a condition for re-hire.

Are you even sure the kid is eligible for the plan? Also, they can change the plan to exclude people under 18. Eligibility is not a protected benefit.

In some states, minors need "working papers" that a bunch of other people have to sign (parents, school, doctor). So if the kid is in this situation, I think the parent COULD make the decision. but IANAL

Yep.

Per the authors of my doc, FT William, in a situation such as mine, it is up to the ER to decide which comp to use (as long as it's documented in the AA.)

I got an AARP mailing the other day...addressed to ME.

In my case this ISN'T a new plan. Plan effective 1/1/2017. They added 401(k) & Safe Harbor in March 2018. Compensation is NOT only while a participant (in any component of) the plan.

And I'm not even a senior yet. Yet. it's coming soon. too soon...

What's the penalty for filing an EZ if you should have filed a "regular" 5500?

Yeah. Never mind this. Another senior moment. Not my best week...

If somebody is making both pre-tax and Roth deferrals, what's the hierarchy for the SH Match? If they are deferring 5% pre-tax and 5% Roth, does the match go 2.25% pre-tax and 2.25% Roth? What if it's like 8% pre-tax and 1% Roth? 4% pre-tax match and 1/2 % Roth? Would it be in the document?

PS plan effective 1/1/2017 added 401(k) and QACA SH on 3/1/18. What comp am I using for the SH? Plan comp says full year and not participation comp. Total senior moment right now.

Company A based overseas, has wholly owned subsidiary in US with a plan. Several employees from parent will be working for the US company. 1) Do they HAVE to recognize service with the parent company? 2) if yes, do we even have to do an amendment? 3) Is the same controlled group testing done for foreign companies (in case this parent owns some or all of other companies not based in the US)? If not, I guess we would list the companies for which service would be credited.

For next year, put in a new comparability formula for the greatest flexibility.

No. You do not get a match on a 402(g) excess.

Plus, this investment would be part of a brokerage window, so the investment isn't necessarily trustee-sanctioned.