imchipbrown

Haven't filed the "EZ" for years. I do the limited info "SF".

I did two VCPs for Non-Amenders. The one with one missed cycles submitted 11/17 and approved 12/01. The other, two cycles missed, submitted 11/21 and approved 12/26.

Sorry folks. Didn't see that I was in the Welfare Benefits Forum.

We used to call them PS58 costs. Dreaded the year end when we had to issue 1099s for PS58 costs. It got really complicated. Actual cost vs cheapest published premiums vs IRS Table rates. I was working in an insurance agency and the agents hated this. Somewhere in the distant future, these costs are supposed to be recouped. I'm too far out of the game to remember the details.

Remember, the deferral limits are on the employee, not the Plan(s). So, you can't defer $19.5k (or $26k) to each of multiple plans.

There's only one company (Corporation A), right? So, doesn't matter where you work. When we get to Mars, I hope our service counts while up there (and during the commute).

Watch the Check box 13 on your W-2 to see if it's marked "Covered" or not. There are income limits for deductible IRA contributions if you're "Covered". This Box can be checked in error. It may or may not matter.

Thanks Flyboyjohn and Larry Larry, I hope you didn't shepherd in the increase in fines for late-filing! Ouchy ouch ouch. If I don't have an ulcer, I'll probably get one now ? Lot's of good stuff in this Act!

I saw this today in a SECURE Act review by Ballard Spahr LLP: b. Nonelective 401(k) Safe Harbor Changes for Traditional and QACA Safe Harbors – The SECURE Act eliminates the notice requirement for safe harbor plans that make non-elective contributions to employees. I can't put my finger on this in the text of the Secure Act text. Can someone confirm this?

Bill, does that mean the doctor shouldn't be "considered a Statutory employee". Doctors don't seem to be "falling into one of 4 categories: agent-driver, full-time life insurance salesperson, home worker, or traveling or city salesperson" . More like an independent contractor?

Yep. Submitted a non-amender PPA on 11/17 and got compliance letter 12/12! Just in time to transfer/terminate before 12/31.

I cut and pasted the new Required Minimum Distribution Life Expectancies from the Proposed Regulations into two Excel tables: Single Life and Joint Life. Seems my Excel skills are better than my html today, so the file is embedded in my website: http://www.peregrinepensions.com At the very bottom of the page, find and click the period (.) right after my email address. It should ask if you want to download the file. Go ahead. It's safe.

From Carol Calhoun's website: 1. 2020 IRS limits are still projected. 2020 Social Security limits reflect the Social Security Administration News Release (October 10, 2019). 2. 2019 limits reflect issuance of IRS Notice 2018-83, 2018-47 I.R.B. 774 (November 19, 2018) and the corresponding Social Security Administration News Release (October 11, 2018). 3. 2018 limits reflect issuance of IRS Notice 2017-64, 2017-45 I.R.B. 486 (November 6, 2017) and the corresponding Social Security Administration News Release (October 13, 2017), as modified by Updated 2018 Taxable Maximum Amount Announced (November 27, 2017). 4. 2017 limits reflect issuance of IRS Notice 2016-62, 2016-46 I.R.B. 725 (November 14, 2016) and the corresponding Social Security Administration News Release (October 19, 2016). 5. 2016 limits reflect issuance of IRS Notice 2015-75, 2015-46 I.R.B. 668 (November 16, 2015) and the corresponding Social Security Administration News Release (October 15, 2015). 6. 2015 limits reflect issuance of IRS Notice 2014-70, 2014-48 I.R.B. 905 (November 24, 2014) and the corresponding Social Security Administration News Release (October 22, 2014). Look at the IRS Notice dates. I'm guessing we'll see them in a week or two.

I don't understand the underlying economics of such a move. But, could file under 29 CFR 2570 Prohibited Transaction Exemption Procedures Employee Benefit Plans

Hate to be the record-keeper for that one.

Is the "loan policy" in the Plan Document or is it referred to by the Plan Document? I've always had a "Loan Policy" that was separate from the Plan Document. The Plan Document Adoption Agreement would simply ask "Are Plan loans allowed?" ( ) Y/N.

Why "Dear"? Agent Montoya will do.

sb0828 - I've never sat at the desk that preparers the payroll. I assume the payroll person at the company inputs hrs/week and checks hourly rates by employee then fires it off the the payroll company. Maybe there's no place to input eligible/ineligible for SHNE. Just a wild guess. Client has let go of the issue for now, so I'll let it die. I can't face another round of "Press 1 for this and 2 for that" through 4 menus, "What's the client's ID and grandmother's birthplace", "Who are you?" "What's the issue?" "Oh, let me transfer you." WAIT, can I get the direct number of the person you're transferring me to? "It doesn't work that way".... ad infinitum until you finally get to the right person who can say "NO".

Bird, You are correct about adding SH during the year. Not the case here. Added in October 2018 for the 2019 year. I assume that the payroll company's programing is geared a certain way according to the check-boxes. They're associating changing their programing as a change to the Adoption Agreement, which as BG5150 points out is unnecessary. Maybe the payroll company needs a 5150.

I have a (former?) client with a national payroll company that also sells a 401(k) plan and service. He remits weekly payrolls to the payroll company and they calculate and mail the paychecks. They debit a company account. The client has never been able to keep other than a catch-up contribution and tiny match in the plan because of non-existant NHCE participation. He's finally having the best business years of his life and agreed to share his company's success with the employees and also solve the 401(k) deferral puzzle with a 3% SHNEC in 2019. His desire is to fund the 3% SHNEC on a weekly basis along with payroll so as to avoid a big deposit requirement at year's end and to have his employees start seeing money go into their 401(k) accounts. (They all have some money there since moving from a pooled account into individual accounts.) He's (I'm) getting push back from the payroll company saying that this can't be done without amending the plan document. They site two Adoption Agreement sections: 2. ADP Test Safe Harbor Contributions For the Plan Year, the Employer will make the following ADP Test Safe Harbor Contributions to the Individual Account of each Eligible Employee as described in item 1(b) above, in the amount of(select one): Option 4: Guaranteed Safe Harbor Non-Elective Contributions. ___3___ (not less than three) percent of the Employee’s Compensation for the Plan Year. 5. Safe Harbor Contribution Computation Period For purpose of applying the ADP Test Safe Harbor Contribution or the ACP Test Safe Harbor Matching Contribution formulas, Compensation will be based on the period selected below (select one)? Option 1: Payroll period. X Option 2: Plan Year. Option 3: Calendar month. Option 4: Plan Year quarter. Option 5: Semi-annual. NOTE: The calculation of a Safe Harbor Contribution based on the computation period selected shall not require the Employer to remit the Safe Harbor Contribution to the Trust earlier than the time required by Plan Section 3.04(D). They fear that making such an amendment (probably to Section 5 above) might throw the plan out of Safe Harbor status, which admittedly would be a disaster. Do you think I should just let go and wait for an early October amendment effective 2020?

Similar (but actual) question. Client has three month wait for 3% SHNE. Employee hired 2/8/19. Three months is 5/8/19. Entry is 1st of month following, or 6/1/19. Employee quits 6/10/19. Employer pays on Fridays. He would pay 6/7/19 and not again until 6/14/19. So "paid" is 7 days or 10 days? Plan's definition of Compensation is W-2. I don't have the Paychex, Inc. Basic Plan Document #03 for a more in-depth reading of Compensation "paid / earned".

Retroactive insurance? Wish they made that! Look for a policy with auto-escalation. A client of mine just got one through Paychex. Bond was issued by Zurich American Insurance Company. Coverage $60K, premium $183 for three years of coverage.

Is this a one- or more-than-one participant plan?

I had a client that received correspondence from IRS that they didn't need to file the 5500-EZ. I had filed as a precaution. The assets had dropped below $250K. Never filed again until terminated.

And isn't it true that he could buy back his shares sometime afterward, say age 71 or later? Tom Poje had some interesting posts/comments about people who became 5% owners later in life (and after 70.5).