imchipbrown

I'm setting up a 401(k) that initially will have no NHCEs. Down the road, some will be hired and eventually become eligible. Plan effective calendar 2003. NHCE hired after 7/1/03. Year of service after 7/1/04 eligible 1/1/05. How is it determined what the maximum deferrals are for the HCEs in 2005? Say the testing method is prior year.

I agree, but would add that Volume Submitter adopters generally have to sign the 17 and 31 amendments.

There's a company in San Francisco called Pensco which will accept "non-standard" type assets into their IRAs. I have absolutely no affiliation with the company.

PRP, To see life expectancy in the GAR table, use an interest rate of 0%.

I don't know if this link will let you in, but give it a try. If you're asked for a user name and password, a click on Cancel may get you in. www.pensionalysis.com/APR.XLS Let me know if it works. Chip Brown BTW, the rates are in the SORXM - Male or SORXF - Female columns on the left. To use them, divide a monthly benefit by the rate to get a lump sum. Multiply a lump-sum by the rate to get a monthy benefit.

Were these contributions to a separate account? Perhaps you can argue that these weren't contributions under the Plan (mis-titled account, should have been taxable). Taxes should have been paid for gains and deductions taken for losses in the ensuing years, but statute years are closed, and good chance losses could be beneficial. Since after tax, should be plenty of basis when distributed. Totally a devil's advocate view, but....

Somewhere around age 51 and 52, depending on if the 6,000 is beginning of year or end of year. Chip Brown

No.

Am I missing something here? Wouldn't you say HCE A has a deferral % of (5600-1000)/70000 or 6.57%. Average becomes 6.036% for HCEs. Refund HCE B roughly $200? Chip Brown

My gut reaction is that the contribution receivable is like a promissory note. You would transfer the "note" along with other plan assets. I see no reason it would be inproper to repay the "note" after it is in the PS plan. My two cents. Chip Brown

Hi Tom, Just wandering through the boards and saw this thread. I think what the question posed was how to do the number-crunching, step-by-step. Chip Brown

Yup

Can't you distribute the entire balance and be done with them?

Have to agree with Blinky, then.

I'll defer to Derrin, but stock could be attributed to their mother or father if under 21 years old.

I may be wrong, but I think that you determine whether a plan is top-heavy for 2002 on 12/31/01. I also think you would use the old method (5 year look back, etc.) Don't quote me... I didn't look this up.

Final triggering event could be the termination of one of the plans. Just a thought.

Have a few clients which have comingled MP/PS assets. One I'm merging has no NHCEs. I'm toying with the idea of drafting currently dated minutes stating the MP and PS were merged, effective retroactively to 12/31/01. Just trying to get a final 5500 in 2001, otherwise 2002 is fine as well. We don't want to back-date anything. Any thoughts? Chip Brown

Pax, That's the one. Thanks for the confirm. Chip

One other issue which may require attention is that profit-sharing money can be distributed in-service, while MP can not until NRA.

I added the new 94 mortality rates to my apr spreadsheet and come up with these rates at 6%. They're monthly. Age 55 157.7916 Age 60 144.9395 Age 65 130.3888 I don't have anything to check them against. Little help? Chip Brown

I agree with the hours assertion. Eligible/ineligible classes still have hours of service. Salary? I've seen prototypes with a choice of either "Plan Year" comp or comp "from Entry Date as a Participant". Check the doc.

Prototypes usually have a spot where you specify eligibility requirements (one year, etc.) and Entry Dates (e.g. 1/1 and 7/1). They also usually have a spot to waive eligibility requirements for employees employed as of x date. Could be before the effective date, sure. These employees then have met eligibility, and come in on the next (first) Entry Date.

You guys are good! Put your pencils to this - Does the 415© limit go from 35k to 40k by itself? Where does the $170K comp limit go by itself? I'm sure I'm not the only one who's curious. Chip

Can't you have them sign an off-the-shelf prototype (say from Schwab, etc)? Even a plain PS effective on the termination date?