Bill Presson

Way back in the day, I shared office space with a wonderful CPA. One day he asked me what my collection rate was. I told him I collected 100% of what I billed. He said "then your rates aren't high enough." I increased my rates 100% and only lost one client. He also told me to never fire a client, but raise your rates to where they leave. He said having someone say "they are too expensive" isn't really a negative. Now, I haven't kept that faithfully and we do let clients go on occasion. But the lesson stuck and I don't think I (or any firm I've owned or worked with) have ever been much below market except for the rare exception.

There may be other parts of the document that you didn't show that would be relevant. You should contact FTW for guidance.

I've been an ASPPA member since 1989 and I'm very partial to them. I've been active in a lot of different areas. I was also a NIPA member from 1990 through 2022. Never felt I got as much from it.

Well, I'm going to argue until I'm forced into submission.

I spoke with Ms Kelsey about that because I don't agree with her interpretation. the rule says three "consecutive years" for 500 hours. It doesn't say overlapping years.

FWIW, Ms Kelsey Mayo spoke on this at ASPPA yesterday and she said that she believes a class exclusion can be used if it's legitimate and not just a cover for everyone that works 500-1000 hours. The examples she used were job description and location.

This is quite different. It's not really pooled because everyone has their own account. Just out of curiosity, I would be interested to know if the trustee is actually managing the accounts differently for each participant based on age or other criteria. It's closer to them all having an outside manager and effective X date, they're on their own. I would be shocked if a blackout notice is needed, though some kind of notice would be wise.

IMHO, this is the hardest thing to grasp when first dealing with DB/CB plans, however once it's clear, it's always clear. But it's then extremely important to help the client learn. And that's one of the toughest parts of client service with DB/CB plans.

I'm always confident but I'm not always right. Open to alternative responses.

Agreed.

I miss you being around. Thanks for the chuckle!

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@ill I answered your questions. This is a board for consultants to discuss various provisions. It's not free advice for people that don't want to pay. Hire someone to provide you expert assistance and quit being cheap.

Then just ignore my last line.

Nice to have you visit, Tom. Enjoy the time!

I'm definitely not one to flout the rules and I despise the "no show" jobs whether it's family or Family (if you know what I mean). But it's also not unheard of for an owner and/or spouse to work for quite some time for their own business without taking a paycheck. If the employer can provide evidence the spouse actually did work during that time and just wasn't compensated, then I think making the spouse eligible on the first paycheck isn't unwarranted. But we don't make those calls just like we don't make the calls on whether someone is an employee or an independent contractor. We provide information and the employer and CPA tell us what's what.

For sole proprietors, the compensation is considered "earned" on December 31, but not technically determined until the 1040 is done. So the deferral deposits can be made up until the 1040 is filed. However, the owner must have made an election to defer on or before the prior December 31 because all 401(k) deferrals have to be elected before the compensation is earned. After-tax contributions have to be deposited by January 31 in order to be credited for the prior year. The Roth conversion typically takes place on the same day of the after tax contribution deposit. You as an employer can still make employer contributions up until your filing deadline. So, it's likely that all your deadlines have passed except for the employer contribution.

We see this done, essentially, when the two plans have maintained a combined trust for years. The assets "transfer" to the DC plan in bookkeeping form on an effective date.

I recommend this: Certified Plan Sponsor Professional It's a designation offered from the Plan Sponsor side of the industry.

If you've been paid for 2022 AND if the 2023 5500 will be for a period of less than 7 months, can't you file the 2022 5500 and indicate the audit will be on the next 5500? Doesn't actually solve the problem but kicks it down the road a bit. You'll still need to get someone to sign.

This is the part your client needs to focus on. Whatever payrolls exist from 10/1-12/31, you need to allow the participants to defer from them. So if the payrolls are on the 15th and the end of the month, you've got an extra few weeks to make things work. If the first payroll in October is 10/6, it's a much shorter time frame.

I wouldn't completely dismiss the possibility of the policy being key man especially in a pooled plan. I do think the existence of the other policy would tend to support that they were intended as individual coverage. But there has to be something to show that the premiums were taken only from the insureds' accunts.

Just for an update. After my post above I called and was told it was approved and mailed. Never got it. Waited another 30+ days and called near the end of June. I was told it was approved and a new copy mailed. Never got it. Finally called on Monday (9/11). Just happened to speak with the same IRS rep that I spoke with in May. He actually was a little perturbed that I didn't get it yet and promised me I would get this one. Good news, I got the new enrollment card yesterday. It was mailed 9/11. Felt a little like Steve Martin when the new phone book arrived.

Agree with Paul. Just move the dollars to a forfeiture/suspense account and have the company use it to offset a contribution. Don't overcomplicate it.