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BG5150

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Everything posted by BG5150

  1. BG5150
    I noticed that yesterday! I was looking it up for someone else in my office, and for whatever reason I decided to do the arithmetic and saw the $480 cost as opposed to the calculated $465.
  2. BG5150
    Yes.
  3. BG5150
    True. It was never unvested money. Those funds should go to an unallocated account (as opposed to the a forfeiture account) and be used to offset future ER contributions. (In fact, EPCRS says there can be NO ER CONTRIBS until the unallocated account is exhausted.)
  4. BG5150
    Ours just says match is discretionary. That's it. We have the option to put in a formula, but why do that? That's the document. The r/k system is a different matter. I would be difficult to allocate different formulae to different groups, but not impossible, I think. (Put people into divisions and run a match for each division, changing the formula as needed)
  5. BG5150
    I think what you do is rend revised tax forms showing $8,000 less distributed. If he doesn't return the money, the ER is on the hook to replace it. It wasn't merely an overpayment, but payment of funds that belonged to others in the plan. Check EPCRS correction of overpayments, thought. Don't forget, he has to send back earnings, too.
  6. BG5150
    Darn
  7. BG5150
    Was this person an NHCE? How much money are we talking about?
  8. BG5150
    And make sure it didn't happen to anyone else!
  9. BG5150
    make it a discretionary match. then you can do whatever you want subject to testing. pretty much
  10. BG5150
    That's why I put "MAY" in my post. I'll go back and edit it to highlight.
  11. BG5150
    Side note: is there a Profit Sharing allocation with everyone as his own group? You MAY not have the ABT available for coverage at all. As with many things in our world, the facts and circumstances will bear it out.
  12. BG5150
    I thought the targeted QNEC was to correct failed ADP/ACP testing. In our document, the coverage remedy is to allocate to those employed at EOY with greatest # of hours. If, after that, it still fails, then allocate to termed EEs with greatest number of hours. The fail safe language mandates that contributions are made. absent that election, you are allowed to use the ABT. However, if ABT fails, I believe you have to resort to the remedy above. maybe with a VCP filing you can try something else with an 11(g) amendment (can you even do one more than 9 mos after EOY?) and cross your fingers.
  13. BG5150
    What if a person takes a partial distribution? Account balance: 40,000 Age 67 Takes a 10,000 distribution Fee: 50 1099-R: 10,000 or 10,050?
  14. BG5150
    ...and don't be surprised if that company stock is unavailable for the hardship as well.
  15. BG5150
    But how can you back date amendments? ;)
  16. BG5150
    Side note: If the (soon-to-be) new owners did not do their due diligence, that's on them.
  17. BG5150
    I agree with Tom. If you know the population, just put them all into a dummy plan, make them all active and code the HCEs properly. The have Relius do it.
  18. BG5150
    Can't they liquidate the asset and take the market value adjustment?
  19. BG5150
    File under the PN on 5558, then amend with correct PN right away?
  20. BG5150
    What about a similar invoice? One dated three months after the one used for the first request.
  21. BG5150
    Where does it say the participant must use the proceeds to offset the need?
  22. BG5150
    Owner is only in his 50's
  23. BG5150
    So, if there are/were no <100% vested distributions, and the plan is kept updated (and teh client continues to pay our fee), do we have any other concerns?
  24. BG5150
    Can't be more than a year, though, right?
  25. BG5150
    Much better now. Thanks!
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