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david rigby

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Everything posted by david rigby

  1. Depend on your relationship to the plan.Didn't the plan (or the plan's trustee, not the company) make the distribution? Seems like the 1099R should show the ID number(s) of the plan, and the SSN of the recipient.
  2. Does this plan have a similar prior event? If not, perhaps it's an opportunity to create, document, and maintain a new administrative interpretation.
  3. State restrictions? who cares? It's simply irresponsible to put at risk the SSN of someone else. In addition to being stupid, it might be an opportunity to get sued, even if your action is not the utlimate cause of identity theft. (BTW, do states have any authority over e-mail?)
  4. Not sure if this is definitive, but look at Q&A15 from 2005 BlueBook: http://www.pbgc.gov/Documents/2005bluebook.pdf "Similarly, an individual with respect to whom the plan has benefit liabilities and any alternate payees with respect to that individual would be counted as one participant."
  5. Any purchase of a commercial annuity by a DB plan must include all relevant provisions in the plan, including (for example) early retirement, J&S conversion factors, etc. Since the annuity must "mimic" the plan, that includes the RMD requirements. BTW, see Reg. 1.401(a)(9)-6, Q&A4.
  6. But it's still late! - See Line 20b on Sch SB - interest penalty
  7. duplicate post: http://benefitslink.com/boards/index.php?s...c=50485&hl=
  8. No. That table is the IRS summary, which they update simultaneously when they release the Notice each month.
  9. 4. Public relations debacle.
  10. I could not locate any such form number. However, see page 4 of the 2011 Michigan Income Tax Withholding Guide for instructions on voluntary withholding: http://www.michigan.gov/documents/taxes/44...AL_336590_7.pdf
  11. Data as of 30-DEC-11 (Friday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.77 3.77 Aa 3.91 3.90 3.91 A 4.24 4.34 4.29 Baa 4.99 5.33 5.16 Avg 4.38 4.34 4.36 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.60 Medium-Term (5-10 yrs) 1.39 Long-Term (10+ yrs) 2.49 ----------------------------------------------------------------------------------------------------------------------------------------------------------- By the way, corresponding Bond Yield Averages for December 28 were (about) 2 basis points higher than 12/30/11. Corresponding rates for 12/23/11 were (about) 18-20 basis points higher than 12/30/11. Some users/reviewers of these items have questioned whether these rates are appropriate for FAS87 purposes. I agree that Moody's rate may not be the best choice. However, I continue to post them as a reference, and not as a recommended discount rate. If you desire to discuss what is an appropriate rate, you may contact me directly.
  12. The "genius" is probably someone who works in real estate, and never heard of RMD.
  13. There was a plan at that date. The form of the plan changed, but the accrued benefit still existed.
  14. No cite, but common sense (OK, that rarely applies to regulatory agencies or Congress) indicates that the EE had an accrued benefit, so RMD should apply.
  15. Some chronology might help: 417(e) was subtantially amended by TRA86.
  16. Rule No. 1. Insurance is not an investment. Rule No. 2. See Rule No. 1. Decide what you want to do: the purpose of life insurance is to provide protection (for spouse, children, estate, etc). Keep investment decisions separate.
  17. In case you have not seen this from 12/22/2011 Federal Register, it's worth reading: http://www.pbgc.gov/documents/2011-32804.pdf Just my opinion, but it seems PBGC has overstepped their authority.
  18. More at this duplicate post: http://benefitslink.com/boards/index.php?showtopic=50431
  19. I have seen plan amendments enacted after plan termination date. IMHO, your proposed amendment should be valid, but you may wish to get opinion from your ERISA attorney.
  20. Sorry, I do not have those. Each day, Moody's posts the prior day's yield rates, but does not save the history. If you want history, you have to pay for it. FYI, Data as of 20-DEC-11 Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.87 3.87 Aa 3.95 4.00 3.98 A 4.28 4.38 4.33 Baa 5.03 5.38 5.21 Avg 4.42 4.41 4.42 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.54 Medium-Term (5-10 yrs) 1.34 Long-Term (10+ yrs) 2.50
  21. I can't imagine why the Plan would not want to inform the participant.
  22. Thanks for posting your experience. Best advice is to make sure the letter includes a date and warning that alerts the recipient to a possible delay. Your tax dollars at work.
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