BG5150

My guess it's the 401(a)4-11g date

Us, too. Just put the dates in both spots int he 5500/8955-SSA section of the 5558

My experiences, too, Mike. However, there are always some under-trained agents or those who way over think things.

What kind of correction could there be? 2017 concluded almost 7 months ago.

We have an Employee who has properly opted out of a 4019k) plan. I know he is counted as includable and not benefiting for coverage. But how do I count him for 5500 purposes? Is he a participant for 5a-b? What about 5d(1) and (2)?

The person must get a total of 3% of 415 wages, which does not exclude pre-participation comp.

If the OP left the company, chances are there was a distributable event, and the loan should be offset...

Is the owner the only non-excludable participant? All the others have less than a YOS or are under 21?

I probably have 2,500 good posts. The others would be silly ones, or dumb ones like my first one in this thread.

Is the distribution eligible for rollover? If not, the withholding can be voluntary. (e.g. an RMD or ADP excess)

missed that piece...

Why is that? "Exemption" might be the wrong word, but a plan that is solely funded with 401(k) and Safe Harbor under 401(k)(12) or (13), and 401(m)(11) are deemed not to be top heavy.

Unless those people will push you over the audit threshold, do you this an Agent would be savvy enough to look at the plan to see if the doc called for 0% vested terms to be either deemed distributed right away or wait 5 years?

FWIW, I don't think the Relius 5500 count report treats them as a participant at EOY if they are termed and fully zero percent vested. (I could be wrong, it's been a long time since I've really checked that by hand.)

If the Service gives you a problem, tell them you are using King Solomon as precedent.

If they are that concerned with an HCE not making an election, have management bug them until they do make an election. Has the plan used current year testing for a while? They might be able to switch to prior year testing and then they will know going into the year (pretty much) what the HCEs as a group can put in. Do they make a match? Or, is the plan top heavy? Would a QACA be a good idea? And, just think, if the HCE is auto-enrolled now at 2%, then they aren't getting to 5% for another 3 years. Lastly, what's wrong with a failed ADP test? That only means the HCE are putting as much as they can into the plan given what the staff does. A passing ADP test means that some HCEs could have saved more.

Doesn't the first loan have to be paid back before a second loan can be taken anyway? Or, does the fact that the participant has a distributable event (eligible for in-service w/d) result in the loan being offset, and thus it doesn't have to be paid back?

Why does the company want to exclude HCEs from auto-escalation? How many HCEs are being automatically enrolled, and how many of them will stay in the program? Management can just send them a e-mail every year: Hey, pick your deferral %!

I agree with 'Cuse. The $6,000 is not catchup until after the ADP test fails. And if you use shifting, you must pass ADP both before AND after.

When ever I see 'GTL' I think about 'Jersey Shore' the MTV show.

I second the call to the plan doc. Some allow for separate elections for bonuses even though the comp is included for plan purposes.

I would think his accountant should be providing these answers.

In a rudimentary earning calculation, you take: Closing balance (-) distributions/loans (-) contributions (-) opening balance (=) earnings Are fees that are deducted from the account figured into the earnings? Or should I account for them like a distribution? I would think I should try to treat them as a sort of distribution because there were shares actually sold. Others just lump them into the final earnings.

So, any additions due to an 11-g amendment are not deductible for the plan year to which it pertains? It's deductible in the year of deposit?

An 11-g amendment is effective as of the first day of the plan year to which it pertains. So why wouldn't a contribution allocated thereunder not be deductible for that plan year? I think there is a reason why the latest date for the amendment is 9 1/2 months after PYE: tax form extensions.