12AX7

I hope you were'nt sitting too close to the stage.

Could have been worse. You could be listening to the 2010 version of Mick Jagger doing the song.

I would suggest reading through this entire thread to get an idea as to how this may affect your preparation of Form 5500.

You didn't mention HEART-WRERA. You may want to check with your document provider to determine what may be needed.

We've took over a plan earlier this year, and recently the trust received a wire transfer of about $1,400 representing accounts for "lost participants" where the disbursement checks were not cashed or deposited. The new CFO does not know to what extent efforts were made to locate these participants. I was thinking of just amending the plan to allow for the autorollover of all amounts not exceeding $5,000. I don't think this is a cutback issue or any issue. I would perhaps suggest that the client send out a letter to each of these individuals using addresses mined from a professional locater service. This is a lot of work for just a few participants, so we just want to deal with it as quickly as possible.

Thanks for the suggestions. I'll start from there.

From the IRS FAQ: Testing 1. What is the testing proposal? (posted 9/28/10) The IRS has proposed that individuals who are not an attorney, certified public accountant, or enrolled agent will have to pass a competency test to officially become a Registered Tax Return Preparer. The IRS expects testing to begin in mid-2011. Tax return preparers who have PTINs before testing becomes available will have until Dec. 31, 2013, to pass the competency test. After testing becomes available, new tax return preparers will be required to pass the competency test before they can obtain a PTIN. Enrolled actuaries and enrolled retirement plan agents will also be exempt if they only prepare returns within their limited practice areas. More guidance on testing, the testing fee, and any other exempt individuals will be available in spring 2011. I recall at ASPPA there was some discussion to obtain the PTIN before the end of 2010 to avoid the compentency test until required by 1/1/14 (assuming this would all apply to Form 5500). However, the FAQ states otherwise.

Does the FT William system store the Filing Signer's User ID and PIN?

We do the same as Austin, although I have heard it argued and have seen amendments done after the 500 hour mark because those proponents claim the benefit is not accrued until the last day of the plan year under all circumstances.

We're considering to go all electronic to distribute Plan Documents, ADP/ACP reports, etc. and collect census data. I'm looking for standalone system suggestions that clients will find easy to use. Sorry if this is not posted in the right forum, but I would imagine that I would get the most responses in this forum. Thanks.

If you see a long line at the FT William booth next week at ASPPA, I'm sure to be in that line waiving a fist full of cash! Oh well, I'm not that extreme, but I would think the line will include current Relius users.

I put a call today into Relius about the problems I'm having E-Filing for clients. I expect to hear back from them after the 15th.

Lord help you today if you're trying to E-File using Web Client. Relius gets a D Minus for EFAST2.

Relius Web Client is grinding to a halt. Nothing but problems with Relius. I do not recommend. Hellloooooooo FT William!

With Relius, I've seen this and a lot more I have time to talk about right now. I don't know if this a specific Relius issue, but with two other vendors, I know this does not happen. My best guess is that there's a bottleneck between the Relius and DOL servers that eventually clears for most 5500s. Some of my clients freak when they get this message.

I know that ASPPA sent a letter to the DOL to request an extension.

That's what I thought. Thanks.

Where in the SF instructions does it reference the "Attachment to 2009 Form 5500 SF Line 10a - Schedule of Delinquent Participant Contributions"?

If Third Party disability pay was showing on the W-2 and the plan was using a definition of comp that includes these amounts, then technically withholding does apply. This is perhaps getting a little off-point, but demonstrates that withholding could occur under these circumstances.

For the fact that you would have a deferral period of less than 3 months for the newly added group, would be my initial concern. This is a good question for the IRS Q & A at ASPPA in a few weeks. Can your client wait until then?

I'm not sure where you would find guidance on this situation. I would perhaps get an authorization from the wife to cease the deductions. The authorization may also contain language to release the plan administrator of any 401 (k) withholding obligations to the participant during the cessation period based on this special election. Perhaps one of the attorneys on the board can suggest a way to do this.

What does the plan document say for the elected comp definition? For example, the W-2 definition of comp in my document includes self-employed income, which I'm assuming is your situation. Maybe one of the accountants here can give insight as to why I also see this on rare occasions.

If in doubt, make an amendment to the plan that specifically addresses this situation.

From what you are describing, it appears that a true-up is to be made for all participants and the employer has perhaps not followed the terms of the plan. I've seen plans in the past that address true-ups for participants that hit the (g) limit, but never in a prototype.