david rigby

Does the DOL determine tax value?

Is there an SSA requirement for the 2009 plan year?

Line 4a of the Schedule H requires an additional table showing the Delinquent Contributions. However, Line 10a on the SF does not require the additional table.

Yes. See DOL reg 2520.104b-1©

While it might be "traditional", it is the prerogative of the plan sponsor. To be precise, the sponsor has always been responsible for choosing the funding method, while the actuary has (until recently) been responsible for choosing the assumptions.

Q1: IMHO, this is a change anticipated by the both the statute and the reg, except that you have a temporary pass. Read both 1.430(h)(2)-1, subsections (e)(1) and (h)(2) and (3).

What does "... or fraction thereof..." mean to you? In my observation, interpolation is nearly universal. Computers have made this task a trivial one.

Prior discussions: http://benefitslink.com/boards/index.php?showtopic=31601 http://benefitslink.com/boards/index.php?showtopic=26083

We celebrate Veteran's Day.

I've learned that my knowledge is often imperfect, so I omit the exclamation points. More importantly, you can gather useful information by a careful search of these Message Boards, often finding that your question has been asked before. For example, http://benefitslink.com/boards/index.php?showtopic=30393 http://benefitslink.com/boards/index.php?showtopic=43403

Not sure the 1099 needs to be "fixed"; it reflects the actual distribution. After the fact, the participant has decided to rollover (whether to IRA or to subsequent employer plan) all or a portion of the original distribution. These are separate transactions. Whatever portion of the orginal amount is not rolled over will (probably) become taxable income. Details of that is the responsibility of the individual, not the subsequent ER or plan. Your questions might be getting pretty close to giving tax advice. Sometimes the best answer is to refer to other sources of information, such as this link to IRS forms and instructions: http://www.irs.gov/app/picklist/list/formsInstructions.html

McKay Hochman's comparison chart: http://www.mhco.com/Library/Articles/2008/...art_103108.html

Data as of 30-SEP-10 (Thursday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 4.54 4.54 Aa 4.71 4.62 4.67 A 4.93 4.93 4.93 Baa 5.45 5.70 5.58 Avg 5.03 4.95 4.99 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.24 Medium-Term (5-10 yrs) 1.16 Long-Term (10+ yrs) 2.92

A fee must be reasonable to be paid by the plan.

IMHO, EFAST2 has nothing to do with the likely response to your question. You (the plan) face the same EBSA/IRS wrath now as you would in any prior year of filing without the B.

Nothing written in front of me, but I recall more than one statement at the 2010 EA meeting: round down. At least one of the speakers was from the IRS/Treasury.

I think this entire discussion is a bunch of bull.

We accept SSNs thru our secure website, and encourage clients/vendors to use it.

Your use of "remove" might be ambiguous. Perhaps a bit more context?

Tom has adequately summarized IRC 410©. Just in case, here is 410(d):

I agree with above comments. A ERW for one NHCE will not be discriminatory, assuming the AFTAP permits a plan amendment. There could be other (associated) PR / HR issues, but those are (probably) not ERISA issues. The Q about fiduciary duty is a good one, and the fiduciary should seek advice from an ERISA attorney.

Is that participant still a participant at EOY?

Steve McQueen would be proud.

414(h) pick-up contributions?

Using the word "source" may a bit fuzzy. Sometimes the Gray Book is really good, sometimes not.IMHO, there is zero chance that the IRS (and the DOL for that matter) will ever take a position different from the Q&A linked above. Simply put, you do not want to fight the IRS on this; you will lose, and the resulting publicity will not be pretty.