mwyatt

Thanks for your replies. Owner would like to grab all of the excess assets (the son will get this eventually when he passes). There were never any NHCEs in the Plan, but is covered by PBGC so will be doing the notification. Will have written memorandum prepared on excess assets stating allocation basis.

Have a Cash Balance Plan terminating, projected to have small amount of excess assets at time of distribution (no 415 issues, etc.). The plan document just specifies that excess assets will be distributed "in a nondiscriminatory manner". In this situation, the Plan only covers the 100% Owner and his son, so both are HCEs and Key Employees. Typically have either allocated on the basis for a regular DB Plan based on present value of 1% of Average Salary times years of participation (maximum 5); in Cash Balance scenario have done same manner where say take 1% of compensation in last 5 years (so hypothetical additional Cash Balance) and allocated on that basis. However, the language "in a nondiscriminatory manner" where only dealing with HCEs looks like we could do anything we wanted and comply, so say ALL excess assets could go the Owner, or ALL to the son, or however the client wanted to apportion. Any thoughts?

Thanks for the recommendation, will check that out.

First, was sorry to hear of Mike Preston's passing. I had been using his PPA Present Values software for checking purposes for a number of years, and with his passing is no longer supported for interest and mortality updates. Any other standalone software alternatives that are recommended?

Yes, ASC has 4.96%, Mike Preston's PPA Pro has 4.87%.

Confused here, IRS notices 2023-66, -72, -76, and 2024-04 showed 2024 ARPA Segment rates as 4.75%, 4.87%, and 5.59%. Now IR Notice 2024-21 has 2024 ARPA Segment rates as 4.75%, 4.96% (instead of 4.87%), and 5.59%. Note that they show the January 2024 segment rates as 4.37%, 4.96%, and 4.95%. Did just leave a voice message with the IRS to figure out if they have a typo on 2024-21. Holding off on doing 2024 valuations for now.

Just took a look at IRN 2023-73 in order to input the new Qx factors into Excel, and notice this year that unlike all prior years, the Qx factors are to 5, not 6, decimal places? Am I missing something here? IR Notice 2023-73 2024 Mortality Tables.pdf

Noted that DOL/IRS have eliminated filing a form 5500EZ as Form 5500-SF (One Man) electronically. Going forward you can now file Form 5500EZ electronically. Just checked ASC/DGEM this morning and see that one of the first questions on EZ screen is whether efiling or paper. That is all well and good, but have filed several final 5500-SF (One Man) filings that had short final plan years in 2020 due to termination already (filed using 2019 series of forms as usual for short final plan years). Question is what to do about those filings given this late sea change in eliminating 5500-SF (One Man)?

Just received email from CCA on 2021 EA meeting. Something seems to be afoot between AAA and CCA. "Due to current uncertainty related to the availability of the Marriott Wardman Park as well as uncertainty about the requirements that Washington DC will impose on large gatherings, the format and specific dates of CCA's Enrolled Actuaries Conference have not yet been determined. The CCA and the American Academy of Actuaries (Academy) have had fundamental differences that we have been unable to resolve regarding the manner in which the Enrolled Actuaries Meeting should be run in the future. As a result, there will no longer be a jointly sponsored Enrolled Actuaries Meeting, and we thank the Academy for their partnership with the CCA in the past."

Actually since everyone has presumably been paid out, unless you want your client having to deal with a plethora of inquires down the road your final 8955-SSA should be reporting under Code D any previously reported Code A's due a benefit.

Not sure if others have run across this recently, but have had a couple clients receiving letters acknowledging that the Comprehensive Premium Filing has been transmitted, but that their records indicate that a premium balance is owed. In most recent case, we uploaded XML file 5/31/2018 and sent in paper check with voucher on the same date. Letter is dated 6/10/2018, but when I look on Account History premium has been credited (with 5/31/2018 date, so can't actually tell when posted). Have to waste time dealing with client's obvious concern that premium hasn't been received, when the PBGC system shows is all settled. I can see sending this letter out if a month has transpired, but 10 days seems to be generating needless worry.

Calendar year client. Let's say profit sharing contribution for 2017 is $190,000 which they will deposit to the Plan in 2018. Similar deposit to be made for the 2018 plan year. Issue is that while they want to make the actual deposit of $190,000 for 2017, they do NOT want to deduct on the 2017 corporate tax return, but rather deduct the 2017 and 2018 on the 2018 return. They did put the 2017 corporate return on extension, so the thinking of they made it within the ordinary time but filed the return before depositing doesn't work. What are the issues here (would combined 2017 and 2018 amounts be subject to the 2018 404 25% limit solely on 2018 compensation for example).

Had an eagle-eyed client bring this to my attention, which was issued today. http://www.irs.gov/pub/irs-drop/n-15-53.pdf which IRS issued in IRS GuideWire dated today (inexplicably the 7/31/2015 IRS Employee Plan News doesn't have this in the issue). Entered 417 rates for 2016 and just ran and looks like fairly trivial impact. From cursory reading of 2015-53, looks like punting the generational tables (and presumably big impact on liabilities) to 2017 (post-election).

Does at least look like the IRS will have these questions incorporated in the 5500/5500-SF (hopefully anyways) looking at language on the IRS page showing the 5500-SUP http://www.irs.gov/Retirement-Plans/Draft-Paper-Form-5500-SUP-for-Plan-Year-2015 From the page: "The IRS anticipates that the Form 5500-SUP will contain the same IRS compliance questions that the IRS intends to add to the Form 5500 and the Form 5500-SF. The Form 5500-SUP will give filers who are not required to file electronically the option to answer these questions on paper." From a real life scenario though, would have to really have a reason to not put these on the 5500 though since the first thing on the 5500-SUP is the EFAST ACK code (which means you would have to e-file, then prepare the 5500-SUP, get to the client for signature, and then mail to the IRS - good luck with that on October 14th). As an aside though, still trying to figure out how many plan sponsors (not TPAs) file over 250 5500 filings annually?

Yes, went through every response on our PDF version and also what was shown on the EFAST search site. Nothing that would indicate that anything but first year for 2013. Given past track record with IRS sending out bogus notices on "late" non-late filings etc., wondering if this is yet another glitchy fishing expedition on the part of the IRS with bad database queries. Interested to see if anyone else starts getting any of these clearly erroneous notices.