BG5150
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Everything posted by BG5150
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Can't not give them the SH. For the PS, use a new comp formula and just give them nothing. (if you pass testing) Is the plan Top Heavy?
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Loan from Rollover before becoming participant?
BG5150 replied to BG5150's topic in Distributions and Loans, Other than QDROs
Do you remember where in the EOB? Which topic? -
Plan allows for rollovers in for employees expected to become a participant but who haven't met the requirements yet. Are these people "Participants" when it comes to the availability of a Participant loan? Definition of a participant is: To me, neither of this conditions have been met.
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But you can't use the ABT if there is fail safe wording, right?
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Check again. Does your document have "Fail safe" language? If so, then you must correct according to the steps there. Otherwise, I think you can pick and choose until you pass. Have you tried the Average Benefits Test for coverage? Sometimes that works.
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Why would sales want to push this type of product? Unless they expect the plan/participants to purchase the annuities through the company.
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[Resolved] RMD Calc For Lump Sum Distribution
BG5150 replied to JMT44's topic in Distributions and Loans, Other than QDROs
If someone is taking a full distribution, I give them the RMD information because that amount is NOT subject to mandatory 20% withholding. We give them the number as ask how much tax they want taken from the RMD (0, 10, 20%) and do the withholding on an aggregate basis (given a pooled account). So, like RBG, the participant gets the RMD number before any 60-day window begins. -
Can you force distributions and have the accounts eaten up as processing fees?
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I'm a legend in my own mind. Does that count for anything?
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Otherwise Excludable Employees on ADP Test
BG5150 replied to ratherbereading's topic in 401(k) Plans
Relius does not look at the hours per se. What drives the the YOS criterion for testing is the Years of Service data element. You can have someone credited with 1,000 hours for 5 different plan years, but if the Years of Service on the Service tab is zero, then that person will be (considered) excludable. The flip side is true, too. If a person never had 1,000 hours entered for any plan years, but the Years of Service field is at least 1, then the person will not be considered excludable. -
The ideal client is the one that pays its invoices on time....
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Don't do a profit sharing?
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- safe harbor
- top heavy
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yes
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They get the TH minimum (as long as they were there at EOY). They do not get the gateway. G/W is for NHCE only.
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But, only if there is an actual contribution that year.
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Larry, it's the former. ER will be adopting the plan this month, with a plan effective date of 1/1/18 but no deferrals allowed until 6/1/18.
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That's true with an exception of 2A. Use 2A if "contributions in the return year were based on...." So, even if the doc has a grouping method for allocation, only use 2A if there were contributions made for the year.
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Call the document provider. They know the doc better than you or us. Tell them what you want to accomplish, and they should be able to tell you if it can be done on that document or not.
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Any issues with a new plan starting deferrals on June 1 with a plan effective date of 1/1? Someone here seems to remember someone opining on why NOT to do this, but we cannot figure out why. Any thoughts?
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Has anyone ever been admonished for a missing or incorrect code on a 5500 on audit or investigation?
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They could always switch to a new plan document that allows it if it is of enough concern?
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Re-read that section about the amendments. Does it say that the amendment cannot affect the benefits accrued of those already participating? That makes more sense.
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Yep. That's the gist of the IRS phone forum on loans from September 2011. Here is the salient paragraph: Here's a link to the transcript: https://www.irs.gov/pub/irs-tege/loans_phoneforum_transcript.pdf That said, has anyone ever had prime +1% ever challenged?
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They pay right away. You can do that on the DOL website.
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What is teh definition of comp for the plan? I don't think 1099 income falls under the any of the usual suspects: 415, simple 415, withholding, or W2.
