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david rigby

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Everything posted by david rigby

  1. It appears Tom has some free time.
  2. I'm with Mike. It appears that A is now a wholly-owned subsidiary of B. Not the same as "no longer exists".
  3. The SOA recently created this website. https://afc.soa.org/ (Sorry, I haven't used it yet.)
  4. Echoing Tom, you might approach this as an "opportunity to clear up a confusion". If the ER has been operating the plan incorrectly, your role is helping educate them.
  5. Carol, although your second sentence rules out a qualified plan, have you considered a DB/DC offset arrangement, thus covering most of the benefit for the rank-and-file in the DC plan? This might allow a fairly large deduction for the HCEs/doctors.
  6. Note that TH testing is based on the total value of the accounts, not the annual contribution. Thus, if TH in one year, the plan might be TH the next year even if the owner makes no contribution. As stated above, a TH deferral-only 401(k) plan is the "worst of all worlds". If so, this owner needs some good consulting advice.
  7. I've faced this precise problem. We could get no insurer to sell a deferred annuity, so the other option was to determine the accrued benefit as an immediate J&S: plan default but assuming a reduction for immediate commencement (probably about age 35). Of course, no such option was in the plan, but the plan termination was being held hostage. The monthly amount was very small (~$10). In hindsight, I wish we had told the participant in advance, as a method to spur a response. ("If you don't return the signed election form within X days, the plan will provide your benefit as an immediate ..... annuity in the approximate amount of $Y per month, and you will have no other options.")
  8. Because the affected people give money to politicians.
  9. IRS Reg. 1.401(a)-20, Q&A27.
  10. Data as of 10/31/2017 (Tuesday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.58 3.58 Aa 3.70 3.69 3.70 A 3.88 3.86 3.87 Baa 4.21 4.37 4.29 Avg 3.93 3.88 3.91 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 1.67 Medium-Term (5-10 yrs) 2.11 Long-Term (10+ yrs) 2.69
  11. Um, please clarify: who is "mother"?
  12. What does the plan say?
  13. FWIW, in my opinion, this arrangement would not be considered a "pension plan" under the accounting standards.
  14. Thanks. Your synopsis is reasonably close to my need, but any SQL usage is not available. Probably only Excel or Access.
  15. I'm looking for a method to track pension payroll information for multiple plans. The desired system would not make the payments, but would produce an output file for another system that makes the payments. The desired system would also be modifiable to create other types of output, such as annual or monthly summaries. I've reviewed Excel and Access templates and found nothing that seems appropriate. Any suggestions?
  16. Peter, At first, this sounded ridiculous. However, upon further thought, I considered it from the perspective of an actuary, and the actuarial profession’s Code of Professional Conduct. In my view, such representation is possible, but might not be advisable; I would tread very carefully. For reference: http://www.actuary.org/content/code-professional-conduct Any actuary who is a member of one of the five US-based actuarial organizations is bound by this Code. Similar rules apply to our friends in the Canadian Institute of Actuaries (yep, their acronym is CIA). If your hypothetical involved an actuary, the COPC would impact the actuary in multiple ways. To my reading, these are the most obvious: Precept 1. Uphold the reputation of the profession. In your hypothetical, the actuary must consider whether the public image of such action might be detrimental, whether or not there was a conflict. Precept 2. Is the actuary qualified to represent the client before the relevant agency? Precept 7. Full disclosure to any relevant parties of an actual or potential conflict of interest, and prior agreement by relevant parties.
  17. What are you trying to accomplish?
  18. Aren't most child support QDRO payments made to someone other than the participant?
  19. Yes, the AP receives the QDRO distribution and it is taxable. But, it seems presumptuous to assume the AP will owe taxes. The PA does not need to know, and should not care, about the AP's tax situation. The PA should provide to the AP exactly what is (probably) provided to any other distributee: the Special Tax Notice and a W-4P.
  20. Has anyone given more thought to this possible one-year delay? What do you think of the de minimis concept? (It looks a bit too easy, so perhaps I'm missing something.)
  21. Terms of the employment contract do not alter terms of the plan document.
  22. Just my opinion: if a DRO needs to be "clarified", it should not become a QDRO. But, perhaps there are other issues or practicalities?
  23. Recent update to the PBGC website, discussing small professional employers: https://www.pbgc.gov/prac/other-guidance/insurance-coverage BTW, is this person a member of any professional associations? Perhaps she can inquire if others have a similar experience.
  24. Perhaps you can help by describing where you found the answer, for the benefit of others.
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