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david rigby

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Everything posted by david rigby

  1. I was not aware that the trustee could decide what goes in the trust. Thought it was the plan administrator.
  2. Others may disagree, but I suggest you process a negative deferral in your payroll system, and let the payroll system take care of the tax withholding issues.
  3. Sorry, I'll have to get back to the rest of your question later, but here is GrayBook 2002-9. Funding: Quarterly Contributions and Application of Credit Balance Plan A has a calendar-year plan year. For 2001, Plan A makes the entire minimum contribution on December 31, 2001. The resulting credit balance on that date is exactly zero. For 2002, Plan A owes a quarterly contribution of $50,000 each quarter. Plan A makes the first two contributions of $50,000 each on April 15, 2002 and July 15, 2002. If these were classified as 2002 contributions (on the 2002 Schedule B), they would exactly satisfy the first two quarterly contribution requirements. However, suppose the actuary reports these two contributions on the 2001 Schedule B as 2001 plan year contributions. Plan A will now report a $100,000 credit balance as of December 31, 2001, which can be used to satisfy the first two quarterly contributions for 2002. In particular, under Q&A-12 of Notice 89-52, the credit balance and interest thereon can be used to satisfy subsequent quarterly contributions once the prior year contributions have been made to generate the credit balance. What is the next quarterly contribution amount due on October 15, 2002, assuming a valuation interest rate of 8%? RESPONSE $46,651. On April 15, 2002, per Notice 89-52, contributions for the prior plan year made by that date can be reflected in the credit balance. Therefore, on April 15, 2002, Plan A has a $50,000 credit balance, effective December 31, 2001. This credit balance is increased with interest to $51,135 on April 15, 2002, and $50,000 of it is used to satisfy the quarterly due. On July 15, 2002, another $50,000 worth of credit balance is created, effective December 31, 2001. This credit balance is increased with interest to $52,128 on July 15, 2002, and $50,000 is used to satisfy the quarterly due. The remaining credit balances of $1,135 on April 15, 2002 and $2,128 on July 15, 2002 are increased with interest to $3,349 on October 15, 2002. Therefore, Plan A must deposit only an additional $46,651 on October 15, 2002 to satisfy the next quarterly due. The above Response is a summary, prepared by representatives of the Program Committee, of the oral responses to the question posed to certain staff members of the Treasury and IRS, which represent only personal views of the individuals who provided them. Accordingly, the Response does not necessarily represent the positions of the Treasury or the IRS and cannot be relied upon by any taxpayer for any purpose. Copyright © 2002, Enrolled Actuaries Meeting All rights reserved by Enrolled Actuaries Meeting. Permission is granted to print or otherwise reproduce a limited number of copies of the material on the diskette for personal, internal, classroom, or other instructional use, on the condition that the foregoing copyright notice is used so as to give reasonable notice of the copyright of the Enrolled Actuaries Meeting. This consent for free limited copying without prior consent of the Enrolled Actuaries Meeting does not extend to making copies for general distribution, for advertising or promotional purposes, for inclusion in new collective works, or for sale or resale.
  4. Yes. If I read your facts correctly, you do not have a CB on 4/15/04 to use as an offset to the quarterly. I don't believe the 12/31/02 credit balance has any bearing on the 4/15/04 requirement. Have you reviewed IRS Notice 89-52? Also, see GrayBook Q&A 2002-9.
  5. I agree. Why would the plan and/or plan sponsor want to do something that created an ambiguous (at best) audit trail, especially when it is so simple to do it right.
  6. The sponsor's first problem might be whether those amounts were included in W-2. Not your problem, but very important to get straight. That may be related to your problem because they may be sending you a year-end payroll record with all adjustments applied. If they did, and you did not notice the discrepancy, get ready to hear the question, "why didn't you notice this earlier?" Of course, one must refer to the plan document definition of Compensation to determine if a problem really exists.
  7. What does this mean? What does the plan say?
  8. PBGC Instructions: http://www.pbgc.gov/plan_admin/forms/PPP20...nstructions.pdf Don't overlook the discussion of Technical Update 00-4 on page 23.
  9. In my experience, most documents define pay at the end of the year (how much did you earn last year?). I fail to see how a zero accrued benefit at BOY yields zero normal cost under UC. As you state, we need not restrict this to UC. "imminent pax attack"? I'm hurt.
  10. Huh? If the accrued benefit is zero at BOY, but not at EOY, how does this give you "no funding"? Have I misunderstood your post?
  11. Earlier related discussion http://benefitslink.com/boards/index.php?showtopic=28656
  12. If your employees are geographically close, organizations such as health clubs, may be willing to offer "group rates".
  13. To discuss, either positively or negatively, any mortality table, you must first know the development of that table: what data was used, what is the intended purpose of the table, etc. Find the document on the SOA website that does this. Read it carefully.
  14. Although this is not my usual type of client, I thought the term cost is just that, the cost. Determine all liabilities; determine all assets. Combining them is what makes a funding method.
  15. Is this recent discussion relevant to you? http://benefitslink.com/boards/index.php?showtopic=29070
  16. The best answer is: don't do it! However, one could refer to page 196 of Authur W. Anderson's excellent book "Pension Mathematics for Actuaries" (second edition). There may also be references in SOA exam study notes.
  17. Are you sure the RMD applies? 5% owner?
  18. It would seem not, at least with respect to accrued benefits. To do so would likely violate one or more existing plan provisions, not to mention 411(d)(6) concerns.
  19. Because many plan sponsors have taken advantage of their ability to have expenses paid by the plan. If the plan participants pay this cost, then the last one standing will bear a significant cost.
  20. Have you checked the yellow pages? http://benefitslink.com/yellowpages/
  21. That is exactly what it means.
  22. Sounds like a question to direct to the "Help" section of your software.
  23. Is it really a change? Or is the term cost just zero? Are you changing an assumption? Look carefully. If you (I'm assuming you are the actuary) consider it a method change, then by all means, report it on the Schedule B. If it does not meet the conditions of Rev. Proc. 2000-40, then IRS approval would seem to be needed.
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