Lou S.

People who turned 70.5 prior to 12/31/2019 have a first RMD year of 2019 RMD and contine to have RMDs "under the old rules" People who do not turn 70.5 until after 12/31/2019 come under the new rules and do not have a first RMD year until the year they attain age 72.

Well it's not quite that you can't use a QNEC the trouble is the QNEC needed to be made by the end of the Plan Year since that's the 12 months following the testing period. At least that's the way I understood the rule but it never seemed to have much practical application. You could have amended to current year testing if you wanted to do QNEC but too late for that now for 2019.

While I agree with you some clients are old fashioned and somehow they are tied to the check book still.

If the wife is rolling it from her late husband's account in the plan to her own account in the plan then yes a 1099-R with code G will be required. Possibly 4G I haven't double checked the instructions on death benefit rollovers.

I'd guess you are looking at an -11(g) amendment to bring some other folks in and it may be expensive. I believe this is why HCEs are often excluded from Davis-Bacon contributions to avoid nasty end of year surprises on testing.

Yes. Prevailing wage contributions are employer contributions subject to nondiscrimination testing.

What does the plan document say? I would think most plans would treat that as a change in classification and the service in one class would count toward eligibility in the other when they changed classification.

If your plan uses the 1000 hour rule and work 1000 in the year you will be credited with a year of vesting service, regardless of when the record keeper gets verification of you working 1000 hours in the plan year.

Do you have any other IRAs? One option might be to roll over the pre-tax basis to your new 401(k) and rollover the after tax basis to and IRA then immediately convert that IRA to the Roth-IRA. Tis wroks if you have no other IRAs. But none of here have enough information about your personal situation to give a complete answer.

Yes it's possible to use full year compensation. On mid-year entry, it would depend on your definition of compensation and whether or not preparticipation compensation is included or excluded. Lastly is the match defined as "per payroll" or "annual"?

Presumably in that case the taxpayer would be on extension and you could use the taxpayers automatic extension no? But you might have a 9/15 filing deadline in some cases instead of 10/15. I mean assuming FYE=CYE=PYE.

$19,000 deferral + $6,800 psp = $25,800 < $27,200 100% of pay so you are OK for 415. Since the PSP does not cause you to exceed any applicable limit (in this case 415) you don't have any deferral to recharacterize as catch-up.

C.B. Zeller your math is correct as it pertains to 415 but if I understand the OP correctly the $12,800 employer contribution would exceed the deductible limit. Unless there are other participants and this cross tested somehow as $12,800 / $27,200 ~ 47% of pay.

The refund is the $3,135.58 plus earnings. The first $2,800 plus earnings is refunded as excess deferral. The remaining $335.58 plus earnings is refunded as excess contribution. You do not need to refund the $2,800 twice as both excess deferral and excess contribution but you will have two 1099-Rs in this case.

What does the document say? If not addressed what do the Administrative Policies say? If not addressed in Administrative Policies, now would be a good time to set and document them for now and the future. If you do allow election, it would be good to also have default order if election is not received timely enough to meet IRS deadlines.

Put them on your prototype now, give them a discount on restatement?

Amend the return.

K2 is correct assuming your plan document offsets top-heavy for matching contributions received. I think most do this, but there is an option to not offset the TH by matching contributions so double check your Plan document terms.

What does your document and or termination amendment say?

I should probably know this but if you are submitting a 2019 Schedule SB before you receive your EA renewal letter, do you use the 17 prefix or the 20 prefix?

I'm not a lawyer, but it may depend on the terms of the Plan and whether or not a beneficiary designation of a spouse is revoked on divorce or if an affirmative new election must be made to change the beneficiary.

It is possible the spouse, now ex-spouse, was once named as beneficiary and your mother did not update the form after the divorce. So from the Plan's perspective they may have a valid beneficiary designation that was never revoked. I'm not saying this did happen, just that it is a possibility.

Does the 10 year rule to non spousal beneficiaries apply to death benefit payments after 12/31/2019 or to deaths after 12/31/2019. That is if a participant died prior to 12/31/2019 but the distribution is not elected or processed until after 1/1/2020 can the non-spouse beneficiary still take advantage of the old "stretch IRA" rules by rolling to inherited IRA or are they locked into the new 10 year payout rule?

I'll join the chorus. This seems totally fine. As long as your new plan allows for loans.

Ok, thanks both. I can see some confusion ensuing in the transition period. Fortunately it's a short transition period.