Bill Presson

Understood that whole list. Just assumed from the prior response, there were no heirs at all. Thanks.

So the "per stirpes" won't apply here? Shame.

I raised this issue the first time I heard that it was a possibility and I thought it was really stupid then. But it's a provision that "raises funds" so it had to be included to make the whole thing happen. I would expect guidance late this year and anticipate that it will be treated like an in-plan roth conversion. My hope is that we can "convert" just the recharacterized amount and leave any related earnings alone.

Your real mistake was assuming that an IRS form with a 11-2022 revision date would actually have updated dates in the form rather than dates from a decade ago.

Yes, I believe all plans will have to be amended to allow for Roth. But I don't understand why you would lose reliance by amending?

Agree with Bri, but also want to say there was likely an issue with the successor plan timing unless the original single ER plan was merged into the PEO. Where did that money go?

We've had clients use The Entrust Group, IRA Resources, Inc., and Equity Trust Company in various situations. Mostly same disclaimer as QDRO above.

Looks to me like it was just a distribution unless the owner is an IRA account.

No. What would justify the 1099? There was no distribution.

If the TPA is running the daily val platform, that would be the reason.

I must admit I've never seen that in 35+ years, so I stand corrected.

I think you think "pass them through" means that the participant can get the cash. That's not the case. It all stays in the plan.

Why couldn't it?

The OP wording just means that the NHCE worked 1000 hours in the first 12 months following date of hire. But vesting is based on calendar (ie plan) years and the NHCE didn't and won't ever have 1000 hours in that vesting measurement period.

There was only one payroll in the last three months?

Top heavy is a problem. If they're participants on the last day, they get top heavy minimums and likely required gateway. Doesn't matter what the allocation requirements are.

Belgarath resurrected an old thread. He isn't talking about the same plan.

Changing from a C corp to an S corp shouldn't require a new TIN. I doubt they created a new entity. They likely just filed form 2553 and elected to be taxed as an S. And the CPA should definitely know the deduction of plan contributions, good grief.

just make sure the w-2 wages are paid to allow the contributions he/she wants to make. The S corp K-1 doesn't count.

Well, they have to be a "distributee" and sounds like they aren't. So they don't even get to enter this section because they aren't tall enough yet to reach the line on the sign.

What if you contacted Penchecks (or another trust paying agent) to see if the trustee could endorse the check to them and they pay it out to the IRA? They may not be able to take the check, but if they can, it keeps it out of the corporate account.

CB is correct.

I would welcome the day...

216F is a 5558 approval. Someone found it behind their desk and saw that it was filed timely so they approved it and sent it out.

Correct.