tymesup

Any allocation okay. I generally do a Memorandum to formalize the allocation.

I sadly have to inform this group that Mike Preston unexpectedly passed away Sunday 5/5 from natural causes. He was knowledgeable and generous with his time.

Both plans used the client's SSN. One is a takeover where we copied last year's EIN. The other provided the SSN as the EIN.

Two clients of ours have received LTR 1072C from the IRS for the plan year ended 12/31/21. These read similarly: Thank you for your 5500-EZ. Your correct EIN is xx-xxxxxxx. You should use this number when filing Form 5500-series returns or Form 5558. If you have questions call or write. Keep a copy of this letter. Cynthia Crowell, Notices/Unpostables Program Manager ** Does anything need to be done for the year ended 12/31/21? Does anything need to be done for the year ended 12/31/22, which has already been filed with the same EIN as for 12/31/21? Thanks for any help.

I had one that lasted over four months

A plan has 70 participants. The plan sponsor is part of a controlled group with well over 1,000 participants. The assets are in a 103-12 IE. The plan has been filing a 5500 for at least the last 10 years. Can it start filing a 5500-SF?

If M was really an employee of the company, it's possible the plan could be amended to provide a benefit to her. Since she was working "for free", it wouldn't be a large benefit. Amending the plan like this would be subject to non-discrimination rules.

Off the shelf, I believe the time of the distribution can be changed. There should be a good administrative reason for the change, as documented by the Plan Administrator. The PA should explain to the participant that the timing cannot be changed again, as the IRS may claim this doesn't satisfy 401(a)(9). It's my money and I need it now is not enough of a reason.

I have some sympathy for mom. Yesterday, she was the Beneficiary, which was worth something. Today, she is not the Beneficiary, which is worth less. Her benefits were cut back, without notice or consent. I have some sympathy for the participant. Did anyone inform him of the consequences of the marriage before he said I do? For this particular plan, do they have to be married for a year before the wife is considered the Spouse? If so, the participant can drag out the misery. I hope the feds don't decide we need to protect the Beneficiary's accrued benefit. Imagine tracking DC accounts and/or DB accrued benefits, for multiple Beneficiary designations and multiple dates.

andre, you might have better success getting a reply on one of the other forums. Perhaps under Health & Welfare Plans?

Do you want to distribute the assets before you receive the IRS determination letter?

Another possibility, which is unlikely, is that the plan's Adjusted Funding Target Attainment Percentage (AFTAP) was less than 60%, which would also cause benefit accruals to cease. If this happened, the plan administrator should have sent the participants a notice.

To correct my old post, insurance is not directly subject to the 415 limit. If the death benefit was equal to the PVAB, then 415 would limit the accrued benefit and the PVAB. My bad.

The participant has the same choices they had before, plus the lump sum, so the participant is better off. The participant can't take the lump sum and buy the same annuity, so the participant is worse off. Under the old arrangement, the participant couldn't take the annuity and get the same lump sum, so the participant is better off under the new arrangement. The participant can evaluate their expected longevity and make a rational choice, so the participant is better off. It's my money, and I need cash now - JG Wentworth.

A plan is allowed to use a male table or a female table or a unisex table to determine actuarial equivalence. What it is not allowed to use is one table for males and another table for females.

Note there is a liquidity requirement for certain underfunded large plans under IRC 430(j)(4).

Feds closed the notice, will not confirm in writing.

The initial inquiry and the current inquiry both refer to plan 006.

Thank you for your inquiry. Even after being received by the EFAST2 system, the return/report filing may be subject to further detailed review by DOL, IRS, and/or PBGC, and the filing may be deemed deficient based upon this further review. The Department of Labor's EFAST2 Contact Center is not able to provide guidance on how to properly respond to correspondence you have received from the IRS. However, you may call the IRS directly at 877-829-5500 if necessary.

I wrote to efast, let's see what comes back.

PN = 006 The 2014 filing is the only one on the DOL website for this PN

Effective date - 1/1/14 First return checked BOY assets - 0

Client receives CP-403 in November, where is your 2013 5500? We respond, no filing required, 2014 was the first year of the plan. Client receives CP-406, where is your 2013 5500, this is your final notice. We respond as above. Will the IRS inform us of the status of our response? If not, is there some way to find out. Thanks for your help.

The plan document may require cash, even if it might otherwise be allowable.

I could see an argument that such an amendment would imply that compensation after the freeze, but before the amendment, should be included. A plan sponsor might not want to pay for such an amendment.