BG5150

Again, though, Relius keys off of the Years of Service field. You can have someone who has a dozen years with over 1,000 hours in the Historical Compensation fields, but Zero in Service on the Service tab, Relius will make them excludable. If you ever have someone you think should/should not be excludable and you are finding opposite results, check that service field. The report that spits out with the excludables is handy when someone is being excluded and you think they shouldn't be.

If the plan covers any of the children, it ceases to be a "one-participant plan."

I find it odd that a pre-approved document would allow something like that. Usually, the choices include "...upon completion of ________ Hours of Service (not to exceed 1,000)..."

Or, you could ask the client for a payroll report from 7/1 to 12/31. Hopefully, the plan isn't that big.

Going forward.

Well, the funds have to come out of the IRA, but the tax forms will be determined by what he does with the disgorged funds. Example: Total distribution $20,100, with $100 excess. So, initially 1099-R, code G, $20,100 1: He returns the money to the plan. remedy: Revise 1099-R to show $20,000, code G. 2: He does not return the money. Revise 1099-R: One 1099 $20,000 code G and on 1099 $100, code 1 or 7, zero withheld.

And the tax reporting cannot be corrected until you know if the guy returns the money or not.

Fix under EPCRS. Excess (and earnings) get moved to a SUSPENSE account. (It is not forfeiture!)

Tom, most docs I've seen give you latitude when it comes to testing comp. This is the first doc that I've seen that states it.

Is that true in all cases? I have a adoption that has a separate place that indicates what comp is included/excluded for ADP/ACP tests. If it says nothing is excluded, would that mean I would HAVE to test with them included, even though the rules say I don't?

Kevin, using that logic, Rollover contributions are not part of a CODA, nor are they safe harbor contributions. So, plans that have a rollover contribution during the year lose the TH exemption?

Test it both ways. Do any of the tests fail? If not, no big deal.

If NHCE, it comes out. if HCE, it stays in.

It is an excess match, and can be corrected under EPCRS. Basically, you remove the excess (plus earnings) and put it in a suspense account and use it to cover the next match deposit. You would not be able to amend 2018 to accommodate a discretionary match.

??

What was with the pink uniforms?

My next question: I know the excess deferrals are included for HCEs but not NHCEs in the ADP test. But what about the Average Benefits Test?

Next question: I know excess deferrals are included in the ADP testing for HCEs but not NHCEs. What about the Average Benefits test?

As long as the funds were not rolled over, I think you are okay.

We have someone who deferred 26,000 in 2018. Obvious 402(g) excess. But do I include the $1500 excess amount in 415? In other words, what is the maximum PS: $35,000 (incl excess in 415) or $36,500 (do not include it if it is distributed)? I believe it is counted, but I cannot look it up in the EOB at the moment.

Tom, what I think everyone meant by that is if you are imputing disparity, you have to consider 100% to the TWB, even if your PS allocation is using less than that amount.

We believe there will be sufficient contributions by the staff to pass ACP. I was thinking that maybe because the VAT is an EMPLOYEE contribution it MIGHT be ok.

We have a client that wants to add a Voluntary After Tax component to a Safe Harbor Match plan (not Roth). The SHM will be the only employer contribution. The top heavy regs say if a plan consists SOLELY of a CODA and the SH, then the plan won't be top heavy. Does the addition of the VAT mean top heavy is back in play?

Is this a client that really needs to be YOUR client? Sounds like more trouble than they are worth.

How can you provide a summary of changes to a plan if you do not indicate what plan it pertains to?