K2retire

But be aware that they often don't actually read line 4 and send a letter to the old plan sponsor insisting that you didn't file a return. At that point you simply direct them to the filing under the new name and point out that it was reported on line 4.

Or use the transition period to keep the plans separately tested and make changes in the next year.

Your real problem is with the funds transferred to IRAs.

It would be both cheaper and easier to put them all in one plan. The only possible down side is that the individual partners might get to see each others contributions.

I would say that your clock starts with the next paycheck after the bonus, not the bonus check itself. I'm not sure that helps, but it might.

What does the plan say about leased employees? That answer could impact a situation like this.

Your statements should show where it is held.

The IRS Voluntary Correction Program.

Better to try it than to not file and know they will get the letter.

They range from about 25 to 600.

But is a terminated employee with no balance still a participant?

Ignoring all of the previously mentioned obstacles for a moment, if you add all of these non-employee participants to the plan, how do you pass coverage and other non-discrimination testing?

A QNEC to pass ADP testing is subject to different rules than a QNEC for a missed deferral opportunity. The required percentage is based on what it takes to pass testing.

I thought it meant that TIAA-CREF was doing both the record keeping and compliance work. Apparently that s not what they think, however.

I think a big part of the reason that the sponsor doesn't want to keep those small balances has to do with distributing all of the required notices to someone who may or may not bother to keep their address up to date.

I agree, that you cannot meet the notice requirement now. That requirement is often what prevents using the reduced correction.

We recently took over as investment advisor on a 403(b) plan with TIAA-CREF. The client is telling us that, although the plan is bundled, TIAA-CREF will not prepare the 5500. They have provided schedules indicating all of the information that needs to go on the form, but will not prepare the actual form. Is that typical of TIAA-CREF -- or is the client misunderstanding something?

Aren't they typically pre-tax because they are part of a 125 plan?

Is it possible that the individual had other W-2 income that reached the FICA limit for the year?

They say they do, but I haven't seen anything yet. They have also asked what we will do if their ERISA attorney tells our ERISA attorney to do it anyway.

They are saying that amending the document to determine compensation using post year end compensation takes care of it.

I once worked for a very wealthy man whose wife told him on their wedding day (back in the 1940s) that he could have a divorce any time he thought he could afford it. They stayed married until he died some 45 years later.

Company A is being acquired by Company B. One of the terms of the acquisition is that A's 401(k) plan must be terminated the day before the acquisition closes. (So far, so good -- they actually planned ahead!) Company A will cease to exist following the acquisition and most employees will transfer to the Company B payroll the following day. Company A pays in arrears and will have a final paycheck for work done before the acquisition a week or so following the acquisition. Because the final paycheck will be after the plan termination date, I have always understood that it is not eligible for deferrals or employer contribution calculations. Company B's TPA insists that it is because it is payment for work before the plan termination. Even if the elections below were changed, I don't believe that would apply in this situation. Have I been mislead by multiple employers and their ERISA attorneys all these years?

If they insist on making the deposits before the end of the year, why not deposit to an unallocated account rather than to the individual participants?

Actually it's pre-tax + Roth limited to $18,000.