chc93

I just noticed this thread. We had one issue once with PDF attachments for one 5500. We think we narrowed it down to how the PDF file was created, but I don't think we found out how or why. In our case, the PDF attachment was side-ways. I think we left it as is when we electronically filed. Maybe that's why printing to a PDF "fixed" the issue. Seems like PDF files can be created in many different ways, and the "coding" of the PDF file is in the file itself.

I recently had to close 2 Form 1099-R filings since I forgot to check the "corrected" box. I called the FIRE support at 1-866-455-7438 (phone number on the main page before going to the Main Menu). The person I spoke with immediately closed the filing, which only took a few seconds. Very painless, as I recall.

I have been entering insurance premiums on Line 8f... Administrative service providers.

For whatever it's worth, in the DOL iFile User's Guide dated March 13, 2017 for EFAST2, they list the Attachment Types. Two of these attachments are "Reasonable Cause for late filing", and "Reasonable Cause for late or missing IQPA Report". I would assume that these attachments would be some kind of statement or letter. I'm not sure I've seen one, or even an example, Maybe you can file the Form 5500 with such an attachment(s).

From what I understood, the DOL calculator is only "correct" (for lack of a better word) if filing through VFCP. If not filing through VFCP, you can use the DOL calculator, but on audit/investigation, you may be subject to additional earnings and/or penalties.

FGC... thank you very much for checking on this...

But, wouldn't that participant count stuff just be a change to the instructions? Like in "What's New"?

Recently, we have seen/heard of some payroll providers that have this "regular" deferral and "catch-up" deferral elections/buckets.

Interesting... I think tuition payments for post-secondary education can be for the next 12 months. If so, I wonder it that would apply here...

Understood. But if the one HCE gets zero, coverage is not an issue, so reasonable classification is also not an issue. If HCE needs contribution, just gotta pass 70% ratio test for coverage, but with each employee in his own group, this might make it easier to pass 70% ratio.

Amend plan to put each employee in his own group. "Group" contributions as desired. If employee sneaks into HCE status, give him zero... cost of making so much income.

Also got this from FTWilliam in a support email in June 2016. ************************ Because we can see the argument for both options, we have reached out to the Internal Revenue Service (IRS) and confirmed with them that the Form 5558 should reflect the technical extension date, not the actual extension date. Thus, it is the opinion of the IRS that the Form 5558 always reflect the 15th ************************

Yes... but then if none is found, then you have pretty good assurance that none was ever filed. So can move forward with that info.

In the past, we have been successful in getting information on the last filed 5500, and even getting a copy of the last 5500 filed from the US Dept of Labor Public Disclosure Room, Room 1513, EBSA, 200 Constitution Ave NW, Washington DC 20210. They told us the last 5500 filed on the phone, but since we wanted a copy, we had to fax the request. Also don't need a power of attorney... public disclosure, after all. Don't know if the request will raise a flag, but if you intend to file the forms anyway, this shouldn't be an issue.

Also note that it doesn't matter when in 2017 she actually attains age 70-1/2. As long as she will attain age 70-1/2 in 2017, any distribution from the plan in 2017 will be subject to 2017 RMD.

RBG... Again, thank you very much.

RBG... Participant A not only entered 03/01/16, but actually started 401k deferrals. As of 04/01/16, does Participant A now have to stop 401k deferrals (no longer eligible to participate) until 1 year of service completed, or can continue with the 401k deferrals.

RBG... very helpful. Thank you very much.

RBG... as you say, there is some confusion in this area, and I'm still a bit confused. (bold/underline) in your post... are you saying that an employee who met the immediate eligibility and is a participant, can now be un-participated (word?) when the 1-year requirement is implemented? Tom's post above looks to be like a prospective application... which is what I would think I would do. I wasn't aware that I could un-participate an immediately eligible participant who didn't meet the 1-year requirement when implemented. Thanks...

Calendar year plan... immediate entry. EE hired Oct 2016. Immediately eligible for plan in Oct 2016. Now, plan amended/adopted in Jan 2017 to change to 1 yr service. Are you saying that this EE is not eligible until after 1 yr service (and maybe never)? I thought an amendment such as this is driven by the adoption date of the amendment, and not an earlier effective date. So this EE stays in the plan as a participant, even if never work 1000 hours in any year. Thanks...

I think it is the last day of the preceding plan year... ****************** 2016 Form 5500-SF instructions: Line 6b. In addition to all of the plan’s assets being eligible plan assets as defined in line 6a, to be eligible to file the Form 5500-SF the plan also must be exempt from the requirement to be audited annually by an independent qualified public accountant (IQPA). Welfare plans that cover fewer than 100 participants at the beginning of the plan year are exempt from the annual audit requirement. A pension plan is exempt from the annual audit requirement if it covered fewer than 100 participants at the beginning of the plan year or under 29 CFR 2520.103-1(d) was eligible to and filed as a small plan for plan year 2015 and did not cover more than 120 participants at the beginning of plan year 2016 and meets the following three requirements for the audit waiver under 29 CFR 2520.104- 46: (1) as the last day of the preceding plan year, at least 95% of a small pension plan’s assets were “qualifying plan assets;” ****************** Is this applicable to the OP question?

For your "twist", I thought that if she attains 70-1/2 in 2016, was still employed on 08/01/16 when she took her full distribution as a rollover to an IRA, and subsequently terminated on 09/01/16, then her 2016 RMD piece is ineligible to stay in the IRA, and has to be "removed".

No experience with that company. But loan payments don't have to run through payroll. Problem with participants writing personal checks and sending in on their own... they inevitably forget. Never saw a direct transfer from participants checking account, but would imagine problems with over-drawn checking accounts, associated fees, etc... maybe worse that participant sending in personal checks and forgetting a few. Any reason for not running through payroll?

I recently read somewhere (can't recall at all, and don't thin it was specific to this situation) that the IRS may view a series of transactions as a single "effective" transaction, such that a $53,000 after-tax contribution to the plan, then an in-service distribution to a ROTH IRA may be viewed as a single ROTH IRA contribution, which is limited to $5,500. Not sure how an in-plan ROTH conversion will be viewed by the IRS.

Years ago, we had a few annual balance forward plans that the plan administrator/trustee set some amount that if the distribution was more, then either wait till the next valuation, do a partial distribution, or do a special valuation. So if the distribution was more than, say 10% of total plan assets, one of the 3 options would be used... or if the distribution was less than, say 10% of total plan assets, the distribution was paid based on the last valuation. The percentage of total plan assets, and the options to be used, were decided by the plan administrator and applied consistently for the plan.