LauraERPA

TPAs and recordkeepers generally charge a distribution fee. Any balance less than the standard distribution fee(s) can be applied toward it.

Apply it toward the distribution fee and be done with it. You've already spent over a $1 worth of your time.

I was able to download the whole survey and instructions. I found it odd they specifically advised recipients not to forward to their service providers. IRS 2024 Survey.pdfIRS 2024 Survey.pdf

Has anyone heard of the IRS's new "Retirement Plan Burden Survey" sent to randomly selected Plan Sponsors? https://www.irs.gov/statistics/rpbsurvey

UPDATE: Found a number on the IRS website; 877-829-5500. Client called and advised us: "WOW, in my 30 years as an accountant that was the easiest call to a government agency that I have ever had. Wait time was less than 4 minutes (as opposed to hours) and the agent actually solved the issue and is sending us a refund check."

We just received notice from our first client that was charged a penalty. We filed their 8955-SSA timely via the IRS FIRE system. The client responded to the IRS notice in early September. The IRS deducted $1,320 from their corporate tax refund. Any updates on this issue?

Employee Leasing company wants to sponsor a 401(k) for their inhouse employees only. Can they exclude employees leased to other organizations? Are there limitations or testing requirements to consider?

A former Profit Sharing Plan client recently returned as his new TPA refused to assist in an IRS audit. While away, the new TPA amended the Profit Sharing Plan effective 1/1/2015 to add 401(k) Safe Harbor provisions. Maximum Deferrals made by 2 HCEs were incorrectly deposited to the profit sharing plan's trust in December, 2014. 2014 W2s reflected the deferrals. Deferrals were then distributed in March, 2015. New TPA reported the distribution (no tax withholding) via 2015 1099Rs (coded P) in January, 2016. Was this the proper correction? Shouldn't the deferrals have been returned to the employer to run through payroll with proper tax withholding and correction of W2s? Does the cross over to a new year change the correction method? Is a VCP submission required for failure to follow the plan document?

Does anyone know if a Plan Sponsor that has previously filed a 5500SF can switch to a 5500EZ? Client has downsized and it is now only husband and wife. The previous TPA continued filing an SF the last couple years even though there were no employees. Can they switch to an EZ? If so, any thoughts on why they should not switch?

Dr X has an arrangement with Company A in which Dr X pays Co A a Y% of his revenue for staff supplied by Co A. Co A leases their employees from Company B. Dr X maintains a 401K and DB plan. All employees meet the regulation requirements regarding leased employees with the exception of primary control; Co A maintains control of employees. However, the regulations specifically name job functions that satisfy the control test; such as, receptionist, wordprocessing personnel, and nurses. The regulations go on to say that professionals that regularly use their own judgement and discretion in the performance of their services and are guided by professional, legal or industry standards do not satisfy the control test. Dr X utilizes Co A's staff to fulfill both clerical and professional positions. Should the clerical employees be treated as leased under Dr X's plans? Does the payment arrangement (% of revenue) make this more of an outsourcing arrangement in which all staff are disregarded under Dr X's Plan? Or do we just have a clever attempt at skirting the issue? Any input is appreciated!

I have been presented with the opportunity to purchase the TPA firm that I currently oversee. I have the advantage of knowing the firm inside and out since I have run it for the last 6 years. I have a good crew of people; all credentialed long term employees. Unfortunately, I do not have the funds for an outright purchase, so an "owner finance" deal is the only option. Any suggestions or options I may be overlooking? Should it be a stock or asset purchase? Really not sure what questions to ask at this point. We've just started talks, so any pointers would be appreciated!

We received the DOL letter today and the scope of the audit is quite invasive. They refer to it as a Section 504 investigation. To summarize, they have requested the following: List of owners and officers to include personal contact information and asset listings List of all clients (active and terminated) since 2006 to include contact info, participant count and assets Marketing materials All contractual agreements with any entity Operation manuals, policies, guidelines, etc. List of 6 largest clients to include all correspondence, documents, files, financial records, participants, assets, etc. All corporate bank accounts and records They also may expand the investigation to include clients/activities prior to 2006.

We received a call from the DOL Auditor, but are awaiting specifics on the scope of the audit. The auditor informed us they were auditing our "TPA operations" and it would take 2 weeks. We've been through audits with the IRS and DOL regarding specific plans and had no problems. We are confident in our operations, but this request just seems unusual and did not come through a specific client. What is their jurisdiction over TPAs? What actions should we take to insure client confidentiality?

Has anyone heard of the DOL auditing a TPA firm???