Lou S.

We send ours in one FEDEX batch and retain the FEDEX proof of delivery.

Luke this is the closest I could find to "official IRS guidance" https://www.irs.gov/pub/irs-pdf/p4278.pdf

Isn't the Uniform Life Table simply a subset of Table II where the beneficiary is assumed to be 10 years younger than the IRA owner?

So you would have no salary while a participant. That's problematic.

If you do not intend to take any salary, how will you establish a 3 year high salary while a participant for 415(b) purposes? I'm assuming this a new plan and not an amendment of an existing plan. We don't typically see such a large range on 1st year either due to various IRS limits. You might want to ask Firm 1 how they are generating such a large range. As for flexibility understand that DB Plans have required contributions, sometimes whether you want them or not.

Short of reviewing the 2018 valuation to see if the required minimum contribution is correct? You are too late for a funding waiver which probably would have been cost prohibitive anyway. Is borrowing funds to make the contribution for 2018 an option?

The loan has about 2.5 years left on it. It's a small plan and the participant is the wife of one of the owners who also process the company deposits. All Participants have maxed out their 402(g) limit for 2019 so to avoid the administrative hassle of logging on every 2 weeks for the rest of the year to simply make her loan payment she wants to make one payment covering all the remaining semi-monthly pay periods in 2019 so it is one less thing she needs to worry about. I personally don't think it should be a problem or complicated but IRS rules on 72(p) and the custodian seem to be giving us blow back and want to treat it as an additional principal payment that doesn't effect any other remaining payments.

You have to give them an option and 402(f) notice at least 30 and no more than 90 days before forcing a distribution is my understanding.

A participant would like to prepay the remaining semi-monthly payments for the remainder of the year. Assume 6 months (12 payments) being made in a lump sum right now to cover all payment from 7/15/19 - 12/31/19. Assume the participant loan program allows for these ad hoc payments and sponsor is OK with it. Is this acceptable from an IRS stand point or is it a violation of 72(p)? I realize 72(p) requires level amortization with payments no less frequently than quarterly but this is essentially paying the payments before they are due not in arrears and will not extend the term of the loan just reduce the overall interest paid. But is this a form over substance thing where it can't be done? If it was just prepaying the next quarter instead of the next 6 months would this be OK?

Is the select group highly compensated employees? (If yes, then you will likely need contribution to some or all NHCEs to pass testing) Does the Plan document allow for varying rates of contributions to different employees? (If no, they you are dead in the water but you might be able to amend for future years.)

Not my area of expertise but I don't think it can go to an Inherited IRA when beneficiary is Estate. I think you have to pay out under 5 year rule as the Estate is not a person.

They can be weekly. Yes you can make the catchup every year starting in the year you reach age 50. The catchup limit like the 401(k) limit is indexed for inflation. Until t hey change the law that is.

If your plan allows for catch-up contributions yes you can contribute up to $25,000 in 2019. If payroll stops you at $19,000 talk to someone in HR as to why you were stopped.

Just be careful of 415(h) should Husband''s ownership increase to "more than 50%" in company 2. Because then even though you don't have a controlled group, he would have one 415(b) and 415(c) limit for Company 1 & 2 combined.

Probably because the Plan allows for ROTH-401(k) contributions would be my guess but why not call T Rowe Price for clarification.

Read the Plan documents. There should be coordinating language that explains how the top-heavy minimum requirements are met.

It seems you have it correct, $42 per month is is $504, since that is under the stated limit of $1,000 you should receive an annual match of $252. It does not say if the match is calculated and deposited each payroll or at the end of the year in a single deposit. On the other hand if you were contributing $420 per month that would be $5,040 for the year. Since that exceeds the maximum $1,000 that is matched the annual match would be capped at $500. In addition it appears that an annual contribution is made that varies based on pay and years of service with the company. This is only a brief summary and the legal plan document and summary plan description might contain additional information that could effect eligibility and amounts.

Why wouldn't you approve. Aren't they threatening foreclosure if not paid? Wouldn't this satisfy avoiding eviction or foreclosure of principal residence?

I think the remedy is to as you say send out the notice as soon as it is discovered with the administrative reason for delay. As a disgruntled former employee you might want to include a withdrawal package that you'll offer to process as soon as the blackout period ends.

Is there a specific reason for him to continue the Plan? I know many years ago we had a client who maintained his 1 man Sole-Prop PSP long after he "retired" largely because he invested in 2nd deeds of trust and it was much cheaper to pay admin fees and document amendments than if was to pay an IRS trustee to hold non-traditional assets. We prepared and he continued to file 5500 under his sole-prop EIN. At some point in the "retirement" phase where he was not making contributions the Plan underwent an IRS audit that was no change. This was in the 90s if I recall correctly so at least at that point the IRS was OK with it. If there is no need to maintain the plan I don't see why he wouldn't formally terminate and roll to IRA to get out of all the compliance work associated with a qualified retirement plan with amendments and 5500 filing requirements.

Loans are not a protected benefit. I don't think there is a problem eliminating future loans for terminated participants.

Wouldn't the over funded pension raise the value of the business which was likely part of the marital settlement? Or do I have it wrong.

I think if it's unclear in the document the Plan Adimistrator would resolve in most favorable way to participant which would be 1st day of the quarter following anniversary in the 12 month period where they worked 1,000. If the document cleary switches to Plan year after the first computation period then they would enter first day of the next plan year. As for the 1.88 MT that was referenced in my AA, your AA may reference a different MT section.

Yes but hard to see a scenario where it would fail if you did testing on a contribution basis. I suspose if you had low paid owners or low paid owners kids in the plan you could run into some situations where it would fail but I'd think in most cases you'd pass pretty easy.

Have you read 1.88 of the Master Text? I believe the answer is there in conjunction with how the AA was completed in the "Eligibility Requirements" Section. Also have you tried posing the question to Corbel/FIS directly, I found they are usually very good about giving responses concerning their document.